Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the taxable years 1975, 1976, 1977 and 1978 in the amounts of $166,730.93, $210,648.41, $225,715.20 and $51,404.14, respectively. The issues for our consideration are: (1) Whether Federal income tax returns for the years 1975, 1976, 1977 and 1978, filed in the names of petitioner and her husband, were joint returns, and (2) if...
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