MEMORANDUM OPINION
MORRISON,
Marc S. Barnes and Anne M. Barnes filed a joint income-tax return for tax year 2003. At all relevant times, the Barneses were husband and wife.
On June 3, 2008, respondent ("the IRS") issued the Barneses a statutory notice of deficiency, determining a deficiency in tax of $54,486, a section 6662(a)
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