MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated August 24, 1994, respondent determined a deficiency in petitioners' 1989 Federal income tax of $30,370 and an accuracy-related penalty, pursuant to section 6662(a), of $6,074. After concessions, the only remaining issue for decision is whether Linda Lagadinos, pursuant to section 6013(e), is entitled to be relieved of tax liability as an innocent spouse. We hold that she is not.
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