Memorandum Findings of Fact and Opinion
INGOLIA, Commissioner:
The respondent determined a deficiency in the petitioner's Federal income tax for the calendar years 1967 and 1968 in the respective amounts of $366.64 and $365.73, and additions to the tax of $13.25 and $13.82. The primary issue before the Court is whether the petitioner failed to report all of her tip income under section 61 in each year.
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