LaBELLE v. COMMISSIONER

Docket No. 9773-79.

47 T.C.M. 1078 (1984)

T.C. Memo. 1984-69

Nancy B. LaBelle v. Commissioner.

United States Tax Court.

Filed February 13, 1984.


Attorney(s) appearing for the Case

Theodore J. England, 500 Esplanade Drive, Oxnard, Calif., for the petitioner. Elaine T. Moriwaki, for the respondent.


Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency of $290,564.37 and additions to tax of $71,991.59 under section 6651(a)1 and $14,528.22 under section 6653(a) for the taxable year 1973. The issues are (1) whether petitioner intended to file a joint return for 1973, and (2) if the return is considered a joint return, whether petitioner qualifies as an innocent spouse under section 6013...

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