Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax of $41,355.40 for the taxable year 1981. The first issue for decision is whether the statutory notice of deficiency issued by the Commissioner showing unreported income earned by petitioner is arbitrary. If we find that the notice of deficiency was not arbitrary, we must decide whether the Commissioner's determination of the unreported...
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