JACOBS, Circuit Judge:
The Commissioner of Internal Revenue has asserted a tax deficiency against petitioner Janet Bliss arising out the 1982 joint tax return she signed with her former husband. Petitioner appeals from an order of the United States Tax Court (Laurence J. Whalen, Judge) sustaining the deficiency. Without objecting to the Commissioner's assessment or calculation of the deficiency or the penalties, petitioner argued before the Tax Court that she...
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