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          in DMA Heitzman, who had been backing him in both businesses, and           
          the financial failure of another financial backer of Autocast.              
               On June 28, 1984, respondent timely issued a statutory                 
          notice of deficiency to Mr. Heitzman and petitioner, determining            
          a deficiency of $55,263 for calendar year 1979.  On September 20,           
          1984, Mr. Heitzman filed a petition with this Court in the names            
          of himself and petitioner, under docket No. 33436-84.  On                   
          September 26, 1984, petitioner filed a separate petition, docket            
          No. 33938-84, in response to the same notice.  In her petition,             
          petitioner disputed the same factual matters as Mr. Heitzman’s              
          petition and raised additional issues of the period of                      
          limitations and relief as an innocent spouse.  On August 9, 1985,           
          Mr. Heitzman filed a motion to dismiss petitioner from the case             
          under docket No. 33436-84.  On September 10, 1985, that motion              
          was granted.                                                                
               On October 10, 1985, the State of Hawaii mailed Mr. Heitzman           
          a notice of assessment based on an increased Hawaii State income            
          tax liability of $11,727 that was based upon disallowance of the            
          deduction with respect to Stonehurst by the Internal Revenue                
          Service.                                                                    
               On December 29, 1986, Wind River sent a letter to the                  
          Stonehurst limited partners inviting them to sign an “Agreement,            
          Release, Consent and Vote to Dissolve” that would terminate                 
          Stonehurst and provide a means to “reduce” the recourse                     
          liabilities that the limited partners had purported to assume in            
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