SCOTT, Judge: Respondent determined deficiencies in petitioner’s income tax for the calendar years 1977 and 1978 in the amounts of $82,955.89 and $49,749.21, respectively. The issue for decision is whether petitioner is relieved from liability under section 6013(e) 1 with respect to the income tax resulting from (1) the inclusion in the income of petitioner and he…
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