Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a $30,823.98 deficiency in petitioners' income tax for 1970, plus additions to the tax of $1,541.19 for late filing of petitioners' 1970 return and $1,541.19 for negligence.
Petitioners do not dispute the amount of the deficiency or the additions to the tax. The sole issue is whether petitioner Earlene Rogers is entitled to be relieved of liability for payment of the deficiency...
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