MEMORANDUM OPINION
COHEN, Judge:
These cases are before the Court on respondent's Motions for Entry of Decision and on the motions of petitioner Mina Bernard (Ms. Bernard) for leave to file amended petitions alleging innocent spouse status under section 6013(e). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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