Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 2

          Tax Court Rules of Practice and Procedure, unless otherwise                 
                                  FINDINGS OF FACT                                    
               Some of the facts are stipulated and are so found.  We                 
          incorporate by reference the stipulation of facts and attached              
               Petitioner resided in Champaign, Illinois, when she filed              
          the petition in this case.  Petitioner married William S. Vriner            
          (Mr. Vriner) in 1980, and they obtained a divorce in 1993. From             
          1984 through 1987, petitioner and Mr. Vriner (the Vriners) filed            
          joint Federal income tax returns, and they reported no taxable              
          income during those years.  The Vriners lived in a house acquired           
          by Mr. Vriner prior to their marriage.  The home was located in             
          an older neighborhood with moderate- to low-priced homes.  They             
          received residential services including telephone, cable TV,                
          garbage pickup, water, and electricity.  During 1987, petitioner            
          had credit accounts with Amoco Oil Co., J.C. Penney, and                    
          Bergners, and a Visa account with Chemical Bank.                            
               Mr. Vriner, along with his parents and siblings, worked at a           
          restaurant owned by his parents (the Vriner restaurant).  When              
          they first met, Mr. Vriner told petitioner that he worked at the            
          Vriner restaurant for a living, and he later told her that the              
          arrangement between him and his family's restaurant was none of             
          her business.  Petitioner never saw a paycheck of Mr. Vriner's              
          from the restaurant, but she assumed that he was being paid.  Mr.           

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