MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency of $268,376 in petitioners' Federal income taxes for 1991 and, by amendment to answer, asserted an increase in the deficiency of $988, for a total of $269,364. We must decide whether petitioner Ella Marie Mitchell (petitioner) is entitled to relief from liability for the deficiency under the provisions of section 6015(b), (c), or (f).
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