Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1971 in the amount of $3,210.22. The issue for decision is the amount, if any, of petitioner's understatement of his 1971 adjusted gross income which respondent determined to be $25,731.70 by the source and application of funds method of reconstructing income.
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