Linda K. Haltom - Page 1

                                 T.C. Memo. 2005-209                                  


                               UNITED STATES TAX COURT                                


                           LINDA K. HALTOM, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17595-03.             Filed September 6, 2005.              

               Donald R. Williams, for petitioner.                                    
               Audrey M. Morris, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HOLMES, Judge:  Jerry Haltom embezzled over $765,000 between           
          1989 and 1994.  He was caught, convicted, and imprisoned for both           
          mail fraud and evading the tax owed on the embezzled income.                
          Before he was caught, his wife Linda worked at home raising their           
          children, running the household, and occasionally earning some              
          money in a part-time job.  The Haltoms filed joint returns that             






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