petitioner filed a joint return with Mr. DiMichele. Each
of those returns states that petitioners' address was "406
Orchard Avenue, Somerdale, New Jersey 08083." That is the
address of a cousin of petitioner's husband. Neither
petitioner nor her husband ever lived at that address.
In fact, petitioner and her husband resided in the house
located at 2010 South 15th Street from 1970 through the time
of trial.
Petitioner's 1984 joint income tax return reports that
the DiMicheles were paid total wages of $26,000 from a
company, Out of the Past, Ltd. According to Schedule W,
Deduction For A Married Couple When Both Work, attached to
the 1984 return, petitioner was paid $6,500 of the wages in
that year and Mr. DiMichele was paid $19,500. Petitioner's
1985 income tax return reports that petitioner was paid
wages of $23,400 by Out Of The Past, Ltd. During 1989 and
1990, petitioner was employed by Quality Sandwich Service,
Inc., and she was paid wages of $11,700 and $9,120,
respectively. In passing, we note that petitioner's Form
W-2, Wage and Tax Statement, for 1985 lists petitioner's
address as "406 Archard Ave., Somer Dale, NJ 08083."
The following is a summary of the income reported on
petitioner's joint income tax returns for 1978 through 1986:
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