Memorandum Findings of Fact and Opinion
WELLS, Judge.
Respondent determined a deficiency in Federal income taxes for taxable year 1981 in the amount of $92,790.30 against Eugene J. Cullinane and petitioner.
The issue to be decided in the instant case is whether petitioner qualifies for relief as an "innocent spouse" under section 6013(e).
Some of the facts have been stipulated for trial pursuant to Rule 91. The...
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