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KELLY v. COMMISSIONER

Docket Nos. 28233-91, 7795-94.

73 T.C.M. 2115 (1997)

T.C. Memo. 1997-99

Edward and Ruth Kelly v. Commissioner.

United States Tax Court.

Filed February 25, 1997.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, Garden City, N.Y., for the petitioner Edward Kelly. Norman Trabulus, for the petitioner Ruth Kelly. Andrew J. Mandell and Lewis J. Abrahams, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

BEGHE, Judge:

In our recently filed Memorandum Findings of Fact and Opinion in these cases (T.C. Memo. 1996-529) (the Opinion), we sustained respondent's determinations of deficiencies, additions to tax, and penalties, and denied the claim of petitioner Ruth Kelly (petitioner) to relief from liability as an innocent spouse under section 6013(e).1 The Opinion...

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