Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Addition to Taxable tax under Year Deficiency Sec. 6651(a)(1) 1971 $ 823.00 $ 206.00 1972 364.00 91.00
The issue is whether petitioners receipt of Federal Reserve notes constituted taxable income to him.
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