Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined deficiencies in Federal income tax of petitioner and his former wife Sarah Jenkins ("Sarah") in the amounts of $1,348 for 1980 and $6,101 for 1981 and an addition to petitioner's 1981 Federal income tax pursuant to section 6653(a)(1) and (2). After concessions, the only issues for decision are whether petitioner is entitled to relief as an innocent spouse pursuant to section...
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