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Commissioner, supra at 1504; Purcell v. Commissioner, supra at
473.
The parties agree that a joint return was filed. The record
also compels the conclusion that the understatement of $55,263
attributable to the items in question was substantial, sec.
6013(e)(3), and we so find.
Respondent has contested each of the remaining issues,
including whether the deficiency exceeds the specified percentage
of petitioner’s adjusted gross income for 1983, her preadjustment
year. Sec. 6013(e)(4)(C). Section 6013(e)(4)(A) requires that
the substantial understatement exceed 10 percent of the claimant
spouse’s adjusted gross income (AGI) for the preadjustment year
if the AGI is $20,000 or less. We find that petitioner’s
adjusted gross income for 1983 could not have exceeded $6,835
even if additional items of income described in the record, which
may well have been reported in other taxable years, are added to
petitioner’s reported 1983 adjusted gross income. The
understatement of $55,263 exceeds 10 percent of petitioner’s 1983
adjusted gross income.
We consider each of the remaining contested elements.
1. “Grossly Erroneous Items of One Spouse”
a. Attributable to Other Spouse
Respondent does not argue that the disallowed Stonehurst
deductions claimed on the 1979 return were not attributable to
Mr. Heitzman. The record shows that petitioner had no ownership
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