Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Year Deficiency 1977 ................ $181,438.00 1978 ................ 115,694.00
The issues are (1) whether income earned in 1977 and 1978 by petitioner, an enrolled member of the Puyallup Indian Nation, from the operation of smokeshops on land held in trust by the...
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