Respondent determined deficiencies in petitioner's income tax for the taxable years 1953 and 1954 in the amounts of $541 and $200, respectively. The statutory notice contained the following explanation:
The exemption claimed by you for your wife, Dorothy Sheppard, has been disallowed because the evidence indicates that she did not qualify as your wife during the year 1953 in accordance with the provisions of Section 25(b) of the Internal Revenue Code of 1939, therefore...
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