OPINION
HALL, Judge:
Petitioner Jorj Judd (Jorj) is a cosmetologist. On March 29, 1979, respondent mailed a statutory notice asserting a deficiency in petitioners' 1976 joint tax return of $1,317. Part of the deficiency related to $2,300 in unreported tips allegedly received by Jorj during the course of her 1976 employment. None of the $1,317 deficiency was attributable to the Federal Insurance Contributions Act (FICA) tax owing on the alleged unreported...
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