SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1963 in the amount of $5,266.93 and an addition to tax under section 6653(a), I.R.C. 1954,
The issues for decision are:
(1) Whether petitioner's former wife received $23,000 of taxable income which she and petitioner failed to include in their joint Federal income tax return for the calendar...
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