The Internal Revenue Service has slappped hundreds of young Washingtonians with hefty tax bills, accusing them of deliberately under-reporting tips they received as waiters and waitresses for Marriott Corporation restaurants.

"It's horrible," said Terri Todd, 20, a University of Maryland student who worked part-time at a Marriott restaurant three years ago. "Every waitress I know is getting audited."

Todd said her case is typical. In 1976 she reported an income of $1,601. But the IRS, using Marriott payroll records, charge slips and restaurant bills, computed her earnings at $2,030 and this month ordered her to pay $230 more in taxes, interest and fines.

"Why me?" Todd complained this week. "I can't believe they would waste time on little people when the big wheels are taking tax loopholes for millions."

The IRS says, however, that "tip" income is a serious, national problem."Of course, it's been taken for granted that under-reporting was a common practice" among waiters and waitresses, said IRS spokesman Robert Kobel. "... And we're taking steps to alleviate it.

The Marriott tip investigation is one of several being conducted by IRS agents around the country said Kobel, who is assigned to the service's Richmond office. "It might be that Marriott is the only one (currently being investigated) in the Washington area, but they are not the only one," he said.

"There is another investigation going in Reno and Las Vegas,"he said. He said. The IRS is selecting the restaurants to be investigated by computer, he said.

The Richmond investigation includes audits of scores of employes of the Bethesdabased motel and restaurant chain, including its Bob's Big Boy, Hot Shoppes, and Farrell's Ice Cream Parlour outlets. Typically the tax bills from the audits total less than $300, although one waitress reportedly was hit with a $1,500 levy.

"They're catching everyone," groused Susan Volpicelli, a college student and waitress at the New Carrollton Bob's Big Boy.

The IRS probe has become a headache for Marriott executives, who say the tax service is examining records from 126 of its more than 400 restaurants. "This is a very serious problem," said Thomas Burke, a senior vice president.

"Marriott's caught in the middle," he said. "We're getting a great deal of ill will from our employes, many of whom are accusing the company of turning them in to the IRS, he said.

The company "had no choice" but to comply because the government could subpoena the records if the company had balked, he said.

According to Barbara Van Blarcum, director of corporate information for Marriott, the tip audits grew out of a routine tax examination of the company.

According to Barbara Van Blarcum, director of corporate information for Marriott, the tip audits grew out of a routine tax examination of the company. From information provided by Marriott, the IRS calculated how many customers a waiter or waitress might have served on a typical day and how much food he sold, according to Van Blarcum. Using charge slips and bills, the IRS then computed how much a waiter or waitress would have earned in tips, assuming 10 to 15 precent of the bill as a gratuity, the IRS said.

But the IRS's formula has been criticized by both Marriott executives and employes who said the workers often received tips which are less than 10 percent of a bill.

"Some people are lousy waiters," said Mary Ann Moul of Vienna, whose daughter was recently audited. "But the IRS lobbed them together.

"They (the IRS) said I should have made $25 a day in tips," said waitress Susan Volpicelli. "But some days were bad and I only made $16. You get a bad station, way in the back with no customers."

Debbie Moul who worked at the Tyson Corner Farrell's Ice Cream Parlour part-time in 1976, said she earned less than $1,000. But the IRS-computing her salary with tips at $1,500-recently billed her for $128 in taxes, fines and interest, her mother complained. "According to the IRS, you're guilty until proven innocent," said Mary Ann Moul this week. "These kids are scared."

An IRS spokesman said the workers can appeal the bills, but many of the Marriott workers say they have only limited incomes and are unable to afford such a step.

Both Volpicelli and Terri Todd blame Marriott for not explaining how to report tips accurately.

Marriott officials rejected as untrue allegations that their workers have been encouraged to under-report tips.

Marriott's Van Blarcum said no new warnings were being issued to the chain's incoming crop of summer employes. "We have always made it clear that the IRS does audit waiters and waitresses. It's been out standard practice all along," she said. CAPTION: Illustration, no caption, By William T. Coulter for The Washington Post