Jack J. Kramer - Page 4

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                  We further hold, based upon the parties' stipulations,                                  
            respondent's concessions at trial, the entire record, and the                                 
            findings below, that Maxine has no deficiency for 1985 and is                                 
            therefore not liable for any additions to tax for that year.4                                 
                                           FINDINGS OF FACT                                               
                  Some of the facts have been stipulated, and are so found.                               
            The stipulation of facts and attached exhibits are incorporated                               
            herein.  The cases were consolidated for trial, briefing, and                                 
            opinion.                                                                                      
                  When petitioners filed their petition for 1985, petitioner                              
            resided in the Federal Correction Institution at Jesup, Georgia,                              
            and Maxine resided in North Miami Beach, Florida.  When                                       
            petitioner filed his petition for 1986 and 1987, he resided in                                
            the Metropolitan Correctional Center, Miami, Florida.  Throughout                             
            1985-87, petitioner was married to Maxine; they divorced in 1993                              
            after having lived separately since 1989.  Petitioner and Maxine                              
            have two children, Benjamin (Ben) and Mark.  Ben is a convicted                               
            drug smuggler, serving a life sentence without possibility of                                 
            parole.  His younger brother, Mark, was convicted and                                         
            subsequently imprisoned for his role in attempting to help Ben                                
            escape from Federal custody.                                                                  




            4Concurrently with the issuance of this opinion, we deny                                      
            petitioners' oral motion at trial to dismiss for lack of                                      
            jurisdiction as to petitioner Maxine C. Kramer in the case at                                 
            docket No. 22457-91.                                                                          



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