Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax in the amount of $464.00 for 1977 and $157.00 for 1978. The issues we must decide are (1) whether petitioner had income from gambling winnings in 1977, (2) whether petitioner has substantiated gambling losses in excess of his winnings in 1977 within the meaning of section 165(d),
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