Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency of $17,262 for 1981 with respect to the joint Federal income taxes of Becky A. Hought (petitioner) and her former husband, Roman T. Hought (Dr. Hought). Subsequent to the issuance of the notice of deficiency (dated March 4, 1986), Dr. Hought paid the Internal Revenue Service $8,631, or one-half of the deficiency, and the interest then due on one-half of the deficiency...
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