Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year ending December 31, 1966, in the amount of $817.67.
Presented for decision are the following issues: (1) Was the division of property pursuant to a divorce decree between petitioner Catherine Showalter (Catherine) and her former husband, a mere partition of community property in which petitioner realized...
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