MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated May 24, 1994, respondent determined deficiencies in Carlos and Trinidad Vega's 1988 and 1989 Federal income taxes in the amounts of $16,550 and $6,701, respectively. The parties have stipulated that the only remaining issue is whether for tax years 1988 and 1989 Trinidad Vega qualifies for "innocent spouse" relief pursuant to section 6013(e). We hold that she does not qualify.
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