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At this point accounting and legal counseling and representation at the same time. An argument that tips, in some or all cases, aren't "compensation received for the performance of non-public services" most likely will work. With no it did not, I'd expect the government to assert this fine. This is why I put an alert label first on this order. I don't want some unsuspecting server to get drawn correct fight your dog can't manage to lose.

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