HAYES v. COMMISSIONER

Docket No. 7176-73.

34 T.C.M. 976 (1975)

T.C. Memo. 1975-223

Patricia S. Hayes v. Commissioner.

United States Tax Court.

Filed July 7, 1975.


Attorney(s) appearing for the Case

Sidney A. Soltz, 19 W. Flager, Miami, Fla., for the petitioner. Kevin A. Suffern, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

The respondent determined deficiencies in the Federal income tax returns of the petitioner for the taxable years 1963, 1964, and 1965 in the amounts of $12,995.57, $9,045.33, and $1,394.92, respectively.

The primary issue for our decision is whether the petitioner qualifies as an "innocent spouse" pursuant to section 6013(e)1 so that she may be relieved of liability...

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