Memorandum Opinion
PARR, Judge:
This matter is before us on cross-motions by the parties for entry of decision.
A brief chronology is in order. The notice of deficiency on which this case is based was sent to petitioner and his then wife, Marie V. Tortu, on December 21, 1981. Respondent determined deficiencies in petitioner's Federal income tax for 1975 in the amount of $20,820 and for 1976 in...
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