Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1964 in the amount of $901.22.
The parties have made certain concessions relating to this deficiency amount. The issues remaining for our decision are as follows:
(1) Whether certain "Christmas tips" given by petitioner to various office hands, delivery boys, elevator starters, doormen, and maitre...
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