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MESSENGER v. COMMISSIONER

Docket No. 1964-69 SC.

28 T.C.M. 1178 (1969)

T.C. Memo. 1969-223

Maxwell H. and Dorothy Messenger v. Commissioner.

United States Tax Court.

Filed October 20, 1969.

Attorney(s) appearing for the Case

Maxwell H. and Dorothy Messenger, pro se, 9802 Winston Ave., Chicago, Ill., William L. Ringuette, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $295.72 in petitioners' Federal income tax for the year 1966 and an addition to tax of $14.79 under section 6653(a), Internal Revenue Code of 1954.

The issues presented for decision are: (1) The amount of tip income received by petitioner Dorothy Messenger in 1966, and (2) if tip income was understated, whether such understatement was "due to negligence or...

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