SETH, Circuit Judge.
I. J. and Ilene J. Wagner appeal from a decision of the United States Tax Court upholding the Commissioner's determination of income tax deficiencies for the years 1969 and 1970. 33 T.C.M. 201. Ilene J. Wagner is a party solely by having filed joint income tax returns for 1969 and 1970 with her husband, I. J.
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