Memorandum Findings of Fact and Opinion
COLVIN, Judge:
The primary issues in this case are the valuation of property for which petitioner claimed a charitable contribution deduction, whether petitioner Stephanie Isaacs (hereinafter referred to as Stephanie Brand) is eligible for relief from tax under section 6013(e) as an innocent spouse, and whether petitioners are liable for certain additions to tax. Section references are to the Internal Revenue Code...
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