Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined a deficiency of $534,836 in petitioners' Federal income tax for the taxable year 1988. The issues for decision are: (1) Whether petitioners failed to report gross income in the amount of $1,990,858 from the sales and exchanges of gold and platinum coins in 1988; and (2) whether petitioner Anette K. Schoch is entitled to relief as an innocent spouse pursuant to section 6013(e).
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