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KATZ v. COMMISSIONER

Docket No. 14651-91.

63 T.C.M. 2476 (1992)

T.C. Memo. 1992-166

Sheila E. Katz v. Commissioner.

United States Tax Court.

Filed March 23, 1992.

Attorney(s) appearing for the Case

Samuel J. Ianacone, Jr., 130 E. Main St., Rochester, N.Y., for the petitioner.

Matthew I. Root, for the respondent.

Memorandum Opinion

PARR, Judge:

This matter is before us on respondent's motion for partial summary judgment with respect to the issue of whether petitioner is entitled to innocent spouse relief during the years in issue pursuant to section 6013(e).1

Background

In her petition, petitioner states the following in support of her case:

On said returns, there was a substantial understatement of tax...

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