Lota Womack - Page 2

          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the taxable years before the            
          Court, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               The issue for decision is whether petitioner qualifies for             
          relief as an innocent spouse under section 6013(e).                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.  Petitioner resided in               
          Jacksonville, Florida, at the time she filed her petition.                  
          Family Life                                                                 
               Petitioner married David H. Womack (Mr. Womack) on October             
          27, 1972, at the age of 18.  Three children were born of this               
          marriage:  David S. Womack, born February 28, 1974; Lota Michelle           
          Womack, born June 14, 1979; and Charles E. Womack, born April 4,            
          1986.  During the years at issue, the Womack family lived in                
          Jackson County, North Carolina, in the small town of Cashiers.              
               For approximately a week to 10 days in December of 1988, Mr.           
          Womack was institutionalized in a mental hospital.  He did not              
          immediately return to the family residence upon release.                    
          Petitioner and Mr. Womack (the Womacks) lived apart from                    
          approximately December 3, 1988, through May 1, 1989.  Petitioner            
          and the children stayed in the family residence in Cashiers,                
          North Carolina.  On January 13, 1989, the Womacks entered into a            





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