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NEARY v. COMMISSIONER

Docket No. 18180-80.

50 T.C.M. 4 (1985)

T.C. Memo. 1985-261

Joanne Neary v. Commissioner.

United States Tax Court.

Filed June 3, 1985.

Attorney(s) appearing for the Case

Jeffrey H. Pasternack, 291 Broadway, New York, N. Y. and Philip R. November, for the petitioner. Martha Sullivan and Robert A. Wagner, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $27,177 in the 1975 Federal income taxes of petitioner and her former husband James V. Neary. The sole issue to be decided is whether petitioner has shown that she is entitled to be relieved of liability for the deficiency under section 6013(e),1 as revised by the Tax Reform Act of 1984, Pub. L. 98-369, sec. 424(a), 98 Stat. 494, 801....

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