Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined a deficiency of $27,922.00 in petitioner's Federal income tax for the taxable year 1981. The issues to be decided are: (1) whether the property known as Sierra Vista was community property or separate property on the date the property was sold; and (2) whether respondent waived his right to proceed against petitioner.
Findings of Fact
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