Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
Respondent determined a $3,784 deficiency in petitioner's 1983 income tax, as well as additions to tax. Petitioner was a resident of Corpus Christi, Texas at the time he filed his petition. The issues are (1) whether petitioner understated his tip income as determined by respondent, and (2) whether petitioner...
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