Mary Lee Sharer - Page 3

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                Petitioner filed separate petitions for each of the notices                  
          of deficiency.  At the time the petitions were filed, and during                   
          the years at issue, petitioner's legal residence was Sacramento,                   
          California.                                                                        
                The subject cases did not proceed to trial.  The parties                     
          filed separate stipulations of settlement for each docketed case.                  
          For tax year 1988, the parties stipulated that petitioner had a                    
          deficiency in tax of $544 and an addition to tax under section                     
          6653(a)(1) of $27, and no additions to tax under sections                          
          6651(a)(1) and 6661.  For tax year 1989, the parties stipulated                    
          that petitioner had a deficiency in tax of $150 and a penalty of                   
          $30 under section 6662(a).  No decisions have been entered as a                    
          result of petitioner's motions for administrative and litigation                   
          costs.  Rules 231(a)(2)(C), 232(f).                                                
                Petitioner is an accountant.  In 1975, she married Michael                   
          Sharer (Mr. Sharer), and one child, Derek, was born of the                         
          marriage in 1986.  Petitioner's marriage to Mr. Sharer was a                       
          stormy one; however, neither she nor Mr. Sharer filed for divorce                  
          or legal separation.  The Court in Sharer v. Commissioner, T.C.                    
          Memo. 1994-453 (involving petitioner's 1986 and 1987 tax years),                   
          found that petitioner and Mr. Sharer were not living together but                  
          were maintaining separate households beginning in early 1986.                      
          The same factual situation existed during 1988 until Mr. Sharer's                  
          death on June 8, 1988.                                                             





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