Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 1979 $5,691.51 $284.58 1980 3,282.68 164.13
The issues for our decision are (1) whether petitioner understated his tip income earned as...
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