Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined a deficiency in the Federal income tax liability of petitioner and her former husband George L. Mothershed for the calendar year 1980 in the amount of $79,585.53 and an addition to tax under section 6653(a) in the amount of $3,979.28. After concessions, the only issues to be tried are whether petitioner qualifies as an innocent spouse under section 6013(e)
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