T.C. Memo. 2000-332
UNITED STATES TAX COURT
HERBERT L. MITCHELL, DECEASED, AND ELLA MARIE MITCHELL,
Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15953-95. Filed October 26, 2000.
John D. Steffan, for petitioners.
Alan R. Peregoy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined a deficiency of $268,376
in petitioners’ Federal income taxes for 1991 and, by amendment
to answer, asserted an increase in the deficiency of $988, for a
total of $269,364. We must decide whether petitioner Ella Marie
Mitchell (petitioner) is entitled to relief from liability for
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