Memorandum Findings of Fact and Opinion
GERBER, Judge:
This is a proceeding for a redetermination of a deficiency in the amount of $9,470, plus additions to tax for negligence ($1,320.20 plus 50 percent of the interest on the underpayment) and late filing ($1,420.50) for the taxable year 1981. The issues to be decided are: (1) Whether petitioner qualifies as an innocent spouse under the provisions of section 6013(e);
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