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Although we incorporate into this Opinion by reference the
findings of fact in our prior Opinion, we restate below certain
of those findings that are relevant to the issues presented by
petitioner's motion for reconsideration, and we further set forth
certain supplementary findings of fact that were not set forth in
our prior Opinion but are, however, based on the record of the
trial of the instant case and relevant to our analysis below.
On November 14, 1979, petitioner and Mr. Crowley were
married. At that time, petitioner was a Canadian citizen and Mr.
Crowley was a U.S. citizen. They were married in a New York
civil ceremony. On November 17, 1979, petitioner and Mr. Crowley
were married a second time in a Canadian church. Prior to her
marriage to Mr. Crowley, petitioner attended the University of
Guelph, in Canada, where she received a bachelor of arts degree.
From August 1977 until August 1979, petitioner worked in Canada
as a life insurance agent first for Prudential Assurance and then
Montreal Life Insurance.
Shortly after the marriage ceremony in Canada, petitioner
and Mr. Crowley returned to New York. During 1980, petitioner
worked for a photographer in New York City for 1 week in exchange
for learning about photography. For 2 weeks, she solicited, by
5(...continued)
the date of the enactment of this paragraph, and no
interest on such credit or refund shall be allowed for
any period before such date of enactment". [Emphasis
added.]
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