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PURCELL v. COMMISSIONER

Docket No. 27793-83.

86 T.C. 228 (1986)

JOYCE PURCELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 26, 1986.

Attorney(s) appearing for the Case

Alan L. Cates, for the petitioner.

Robert P. Crowther, for the respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1977 and 1978 in the amounts of $82,955.89 and $49,749.21, respectively. The issue for decision is whether petitioner is relieved from liability under section 6013(e)1 with respect to the income tax resulting from (1) the inclusion in the income of petitioner and her then husband of (a) dividends resulting from amounts paid by a corporation...

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