Joyce Aston - Page 3

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          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and attached exhibits are            
          incorporated herein by this reference.                                      
                                  FINDINGS OF FACT                                    
               Petitioner resided in Long Beach, California, at the time she          
          filed the petition.                                                         
               Petitioner is a citizen of the United Kingdom.  After working          
          as a secretary, petitioner joined the Royal Navy, where she met             
          Gordon Aston.  They married in 1946.  Petitioner and her husband            
          originally resided in Manchester, England.  Petitioner stayed at            
          home for several years to care for their two children, and                  
          subsequently attended a training college for teachers.  Petitioner          
          became a college instructor.  Her husband was a police officer with         
          the Manchester City Police Force.                                           
               In 1972, Mr. Aston retired and moved with petitioner to the            
          Isle of Man, off the coast of England.  At that time, petitioner's          
          daughter resided in the United States.                                      
               In 1977, petitioner's son moved to the United States.  In              
          1979, petitioner and her husband sold their house on the Isle of            
          Man and moved to California to be closer to their children.                 
               Until his death on December 31, 1984, petitioner's husband             
          handled the couple's financial affairs.                                     





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