Carl Dimichele and Eileen Dimichele - Page 4

                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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