Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined income tax deficiencies of $22,829.61 for 1976, $16,300.42 for 1977, $15,511.74 for 1978, and $18,218.61 for 1979.
The sole issue for decision is whether Judy McCalister, formerly known as Judy Pettinato, qualifies as an innocent spouse under section 6013(e). We hold that she does not.
Section references are to the Internal Revenue Code in effect during the years...
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