Memorandum Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $6,863 in the joint Federal individual income tax of Ellen Levin and Morton Levin for the taxable year 1981. Although the petition named both Ellen Levin and Morton Levin as petitioners, the case was dismissed for lack of jurisdiction as to Ellen Levin, who did not sign or subsequently ratify the petition. For convenience, the 1981 joint return will be referred to as petitioner Morton...
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