Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioner's income tax for 1979 of $1,000. The sole issue for our determination is whether petitioner is subject to the recapture provisions of section 44(d)(1).
Findings of Fact
Some of the facts were stipulated and are so found. Petitioner resided in Mt. Pleasant, Michigan, when her petition was filed.
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