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SILVERMAN v. COMMISSIONER

Docket No. 18502-91.

67 T.C.M. 2631 (1994)

T.C. Memo. 1994-153

Harriet Silverman v. Commissioner.

United States Tax Court.

Filed April 13, 1994.

Attorney(s) appearing for the Case

Bertram Gezelter, 161 No. Blvd., Flushing, N.Y., for the petitioner. Andrew Mandell, for the respondent.

Memorandum Findings of Fact and Opinion

BEGHE, Judge:

Respondent determined a deficiency of $107,280 in petitioner's 1977 Federal income tax.1 The sole issue for decision is whether, under section 6013(e),2 petitioner is entitled to "innocent spouse" relief from joint and several liability for the deficiency. For the reasons that follow, we hold that petitioner is not entitled to such relief.

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