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tax return; it constitutes their joint income tax return
even though P’s spouse did not sign it. See sec. 6013,
I.R.C. 1986.
Gerald Dennis Strong, pro se.
Innessa Glazman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined a deficiency in
individual income tax and an addition to tax under section
6651(a)(1)1 (failure to timely file tax return) against
petitioner for 1994 in the amounts of $108,941 and $5,573.85,
respectively.
After a concession by respondent,2 the issues for decision
are as follows:
(1) Whether under the doctrine of res judicata
petitioner is barred by the order in In re Strong, No. 97-2-
4433-DK (Bankr. D. Md., Aug. 25, 1998) from contesting his
tax liability for 1994, except as that may be affected by
the filing status of his 1994 tax return.
1Unless indicated otherwise, all subtitle and section
references are to subtitles and sections of the Internal Revenue
Code of 1986 as in effect for 1994.
2Respondent concedes the sec. 6651(a)(1) addition to tax.
See infra note 4.
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