Stanley B. and Rose M. Whitten - Page 3

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          v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.                        
          Commissioner, 79 T.C. 340, 344 (1982).                                      
          As explained in more detail below, we agree with the parties                
          that the issue before us is ripe for summary adjudication.                  
          The following is a summary of the relevant facts that do not                
          appear to be in dispute.  They are stated solely for purposes of            
          deciding the pending motions and are not findings of fact for               
          this case.  Fed. R. Civ. P. 52(a); Sundstrand Corp. v.                      
          Commissioner, supra at 520.                                                 
          Stanley B. and Rose M. Whitten (petitioners) are husband                    
          and wife who filed a joint Federal income tax return for 1991.              
          At the time that their petition was filed in this case,                     
          petitioners resided in Northbrook, Illinois.                                
          Stanley B. Whitten (petitioner) is a criminal investigator                  
          with the United States Securities and Exchange Commission.  He is           
          also a nationally recognized cruciverbalist who has constructed             
          crossword puzzles that have appeared in newspapers and magazines            
          throughout the United States, including the Chicago Tribune, the            
          New York Times, and the Washington Post.                                    
               In early 1990, petitioner learned that the staff of the                
          "Wheel of Fortune" television game show was coming to Chicago,              
          Illinois, to interview and select contestants to appear on the              
          program.  Petitioner applied for and received an invitation to              

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