O'SCANNLAIN, Circuit Judge:
Joseph Edelson and his wife Harriet Edelson appeal the tax court's decision dismissing their petitions for federal income tax redetermination, upholding the Commissioner's issuance of deficiencies and additions to tax against Joseph for fraud, and finding Harriet liable for a portion of Joseph's taxes as a transferee. We affirm.
FACTS AND PROCEEDINGS BELOW
The Edelsons filed joint returns before 1975, but filed separately...
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