MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $8,200 for the taxable year 1993. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
After concessions by petitioner, this Court must decide whether petitioner is liable for income tax on $61,983, her distributive share of partnership income.
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