MEMORANDUM OPINION
NIMS, Judge.
Respondent determined deficiencies and additions to tax with respect to the Federal income tax of Stella Adler Wilson (decedent) for the taxable years 1980, 1981, and 1982. Decedent, the original petitioner, died in 1992, and by Order dated October 21, 1997, her estate was substituted as petitioner.
This case initially involved a number of partnership-related issues. However, these have all been resolved by stipulation...
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