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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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