MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge.
The petitioners, Laurel Alterman and William A. Gibson, filed joint income-tax returns for 2010 and 2011. On March 13, 2014, the respondent (hereinafter, the "IRS") issued a notice of deficiency to Alterman and Gibson. The notice of deficiency made adjustments to the income of a...
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