Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $32,374 in petitioner's Federal income tax for 1987. The sole issue remaining for decision is whether petitioner is entitled to relief as an innocent spouse under section 6013(e).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
Findings of Fact
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