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training program. In 1964, upon completion of the above-
referenced secretarial training program, petitioner began working
for the Louisiana State Department of Transportation (LSDT) as a
secretary in LSDT's legal department. She remained with LSDT
until January 1988, when she began working part time as a
secretary in a law firm located in Baton Rouge, Louisiana.
Petitioner quit this part-time position shortly after obtaining
it. Petitioner's income from wages during the taxable years at
issue were as follows:
Year Wage Income
1985 $13,426.66
1986 13,413.74
1987 14,394.71
1988 22,775.85
1989 10,800.00
1990 9,768.00
Like petitioner, Mr. Goings earned a high school diploma.
Thereafter, without earning a degree, he attended three State
universities between June 1964 and April 1969. Following a short
recess, Mr. Goings returned to college and obtained a bachelor's
degree in general studies in 1973. Commencing in 1969, Mr.
Goings was employed by Allied-Signal, Inc. (Allied). Allied,
among other things, produced polyethylene resin. During the
years at issue, Mr. Goings was Allied's distribution manager.
Mr. Goings received the following income from wages during the
years at issue:
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