Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The petitioner, Nicholas Mastres, a hotel banquet waiter, filed joint income tax returns with his wife, Lillian Mastres, for the years 1952, 1953, 1954 and 1955 with the district director of internal revenue, Brooklyn, New York. In these returns he estimated the amount of gratuities (tips) he received and reported as tip income for said years the sums of $750, $600, $600 and $800, respectively.
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