Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency of income tax in the amount of $21,339.66 against petitioner and her former husband, Sanford R. Shapiro, for the calendar year 1977. After concessions, the only issue remaining is whether petitioner qualifies for relief under section 6013(e), Internal Revenue Code of 1954.
Some of the facts herein were stipulated and are so...
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