Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a statutory notice dated June 26, 1981, respondent determined a deficiency in the amount of $550.00 in petitioner's Federal income tax liability for the year 1978. The issues for decision are: (1) whether petitioner was engaged in the trade or business of gambling in 1978, the resolution of which determines whether petitioner is subject to the minimum tax and (2) whether petitioner is subject to the...
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