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SIVILS v. COMMISSIONER

Docket No. 26762-81.

86 T.C. 79 (1986)

GEORGIA C. SIVILS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 27, 1986.

Attorney(s) appearing for the Case

Robert W. Schivera, for the petitioner.

J. Mack Karesh, for the respondent.

OPINION

WILLIAMS, Judge:*

The Commissioner determined deficiencies in petitioner's Federal income tax and additions to tax for calendar years 1973 through 1977. After concessions, only a deficiency of $20,021.71 in petitioner's Federal income tax for 1977 remains in controversy. The sole issue that the Court must decide is whether the innocent spouse relief provision of section 6013(e)1 permits...

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