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September of 1983. The Audes filed joint Federal income tax
returns for each taxable year at issue.
Petitioner was born on August 10, 1951. In 1969, she
graduated from high school with approximately a 2.0 grade point
average. After graduating from high school, petitioner worked
primarily as a receptionist in the Los Angeles area.
In August of 1969, petitioner married for the first time.
She had a son, Michael, in January of 1972. Petitioner divorced
in 1973; however, in August of 1974, petitioner and her first
husband had a second child, who was later given up for adoption.
In 1975, petitioner worked as a receptionist for the
Landsberg Company (Landsberg). There, she met Mr. Aude, who
worked as a salesperson for Landsberg. At the time, Mr. Aude was
divorced with two children from a prior marriage. In February
1976, petitioner and Mr. Aude, who was then 33 years old, were
married. Petitioner and Mr. Aude had two sons: Peter, born in
December 1978, and Erik, born in April 1980.
During her marriage to Mr. Aude, petitioner worked as a
housewife and mother.3 She had the role of taking care of five
children: Michael, Peter, Erik, and Mr. Aude’s two sons from his
prior marriage (who lived part of the time with petitioner and
Mr. Aude).
3 In 1980 and 1981, petitioner had a part-time job selling
books for World Book--Childcraft International, Inc. However,
petitioner only earned $37.68 in 1980 and $144.17 in 1981 from
this part-time job.
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