Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1964, 1965, and 1966 in the amounts of $2,703.27, $1,271.21, and $1,364.31, respectively, and imposed an addition to tax under section 6651(a) for 1964 in the amount of $675.82.
The issues presented for our decision are as follows:
(1) Whether petitioner had unreported income of $11,847.27 and $6,823.28 in 1964...
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