Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined, by statutory notice of deficiency dated August 22, 1984, a deficiency of $266,582 in petitioners' 1981 Federal income tax, which has been reduced, by stipulation of the parties, to a deficiency of $40,065. The sole issue remaining for decision is whether Alice P. Jones (petitioner) is entitled to relief under section 6013(e)
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