Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a statutory notice of deficiency dated April 13, 1984, respondent determined a deficiency in the 1980 Federal income tax liability of petitioner and petitioner's now-deceased wife, Eleanor H. Oswald, in the amount of $95,806.54. By amendment to his answer, respondent increased the deficiency to $105,494. At trial, we granted respondent's motion to dismiss with respect to Eleanor H. Oswald due to her...
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