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11. Beginning on or about March 15, 1988, Cushing
Regional Hospital, upon the instructions of Dorothy E.
Wells, began to make the income earned by her payable
to an entity named Summit Resources. All of the
$7,847.49 paid by Cushing Regional Hospital to
petitioner Dorothy E. Wells in the taxable year 1988
was made payable to Summit Resources.
12. At some point in 1988, Cushing
Medical Clinic, Inc., upon the instructions
of Dorothy E. Wells, began to make the income
earned by her payable to an entity named
Summit Resources. All of the $8,940.00 of
the $12,161.75 paid by Cushing Medical
Clinic, Inc. to petitioner Dorothy E. Wells
in the taxable year 1988 was made payable to
Summit Resources.
13. For the taxable year 1989, all of the income
earned by Dorothy E. Wells from Cushing Medical Clinic,
Inc. and Cushing Regional Hospital was, upon her
instructions, made payable to Summit Resources.
14. The address for Summit Resources given by
petitioner Dorothy E. Wells to those payors was 5147
South Harvard, Suite 248, Tulsa, Oklahoma 74135, which
is the address of a mailing service called "The Mail
Suite".
15. Petitioner Dorothy E. Wells was an
independent contractor during each of these four years,
and none of the payors withheld any federal income tax
from the income they paid to her, based on her
instructions to them.
16. Petitioner Dorothy E. Wells has not paid any
federal income tax for the taxable year 1986, 1987,
1988 or 1989.
17. On July 6, 1990, petitioner Dorothy E. Wells
signed and mailed a letter to the Internal Revenue
Service, Austin, Texas, attached to which were five
Forms 1040 for 1985, 1986, 1987, 1988 and 1989. A copy
of the same letter was attached to each Form 1040, and
the only difference among the letters was that the
petitioner underlined the appropriate year in the
second line of the letter. A copy of the letter (the
letter in which 1986 was underlined) is attached hereto
as Exhibit 3-C, and a copy of each of the Forms 1040
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