Anne C. Somervill - Page 3

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          1976 in the amount of $1,682.  Furthermore, the notice disallowed           
          the ordinary losses claimed from an investment in Progressive               
          Properties, a partnership, in the years 1980, 1981, and 1982.               
               Petitioner was raised in a small town of 1,500 people.  She            
          completed high school and continued on to junior college for 2              
          years.  Petitioner then attended Northwestern University in                 
          Evanston, Illinois, and was awarded a bachelor of arts degree in            
          psychology.  Immediately after completing college, petitioner               
          worked at Northwestern University's medical school answering                
          phones in the registrar's office.                                           
               Petitioner met and married Robert Somervill, a medical                 
          student at Northwestern University, in 1957.  Their first child             
          was born 13 months thereafter, in 1959, their second in 1962,               
          their third in 1964, and twins in 1965.  Petitioner and her                 
          family moved to San Benito, Texas, in 1967 and remained there for           
          all of the years in issue.                                                  
               In 1977, petitioner received her real estate license and               
          began working in a real estate office as an agent.  Petitioner              
          testified that she was not a successful agent, and that her first           
          sale took place in 1983.  However, a joint Federal income tax               
          return filed for the 1977 tax year reflects a net profit from               
          petitioner's real estate activity.  In 1983, petitioner became a            
          real estate broker, the requirements for which are more                     
          burdensome than those for a real estate agent.                              






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