Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the years 1977 and 1978 in the amounts of $65,053 and $225,402, respectively.
The sole issue for decision is whether petitioner received unreported income in the amounts of $163,920 and $348,264 in taxable years 1977 and 1978, respectively.
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