Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's income taxes for the taxable years 1977 through 1980 in the amounts of $1,426.00, $1,288.00, $1,992.00, and $3,410.40, respectively. After concessions the only issue for determination is whether petitioner qualifies under section 6013(e)
Findings of Fact
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