Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined a deficiency in petitioner's and her former husband's Federal income tax liability in the amount of $29,370.20 for 1972 in a notice of deficiency dated January 29, 1976. Petitioner's former husband, Steven Singer, filed a petition in bankruptcy on September 24, 1975, which bankruptcy proceeding is still pending. Petitioner, Emily Bell, is not a party to that proceeding. However,...