Hans H. and Cheryl E. Hammann - Page 5

                                        - 5 -                                         
                    Year                      Amount                                  
                    1983                     $39,174                                  
                    1984                     41,391                                   
                    1985                     44,402                                   

               The earnings from Hans Hammann's employment with the union             
          accounted for the majority of petitioners' income during those              
          years.  Petitioners reported adjusted gross incomes, taxable                
          incomes, and Federal income tax liabilities on their 1983, 1984,            
          and 1985 Federal income tax returns as follows:                             
               Year   Adjusted Gross Income  Taxable Income   Tax Liability           
               1983           $30,190           $19,094           -0-                 
               1984            22,192             9,242           -0-                 
               1985            13,120              (661)          -0-                 

               Cheryl Hammann was not employed during 1983, 1984, or 1985.            
          In 1982, she enrolled in an undergraduate premedical program at             
          an unspecified school presumably in the San Francisco area.                 
               According to Cheryl Hammann, her husband worked in excess of           
          100 hours per week as a union official and was under a great deal           
          of stress as a result of his position.  Apparently, the pressures           
          of his employment caused Hans Hammann severe health problems                
          that, together with financial setbacks, caused petitioners to               
          move from the United States to Germany in 1986.  Prior to leaving           
          the United States, Cheryl Hammann gave birth to a son, Andreas              
          Hammann, on January 6, 1986.  Neither petitioner has returned to            
          the United States since.                                                    








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