Supplemental Memorandum Findings of Fact and Opinion
WILES, Judge:
The U.S. Court of Appeals for the Fifth Circuit remanded this case for us to determine whether certain income is attributable to petitioner or her spouse for purposes of applying the "innocent spouse" statute, section 6013(e).
Findings of Fact
Some of the supplemental facts have been stipulated, and those facts are so found.
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