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the years at issue, (1) Mr. Hardy was employed in the construc-
tion industry; (2) petitioner was aware that Mr. Hardy was
employed in the construction industry; (3) Mr. Hardy was paid
income from his employment; and (4) he used at least a portion of
that income to pay at least some of the living expenses.11 In
addition, the parties stipulated: (1) Income totaling
$48,264.38, consisting of wages and interest, was reported to
respondent as having been paid to and/or earned by Mr. Hardy
during 1983; and (2) income totaling $22,986 and $45,004, con-
sisting of wages, unemployment compensation, and interest, was
reported to respondent as having been paid to and/or earned by
Mr. Hardy during 1984 and 1985, respectively. Petitioner has
made no attempt to, and has not, come forward with any evidence
indicating that that income was not paid to and/or earned by Mr.
Hardy during those years. Indeed, petitioner does not even
dispute that the income that was reported to respondent as having
been paid to and/or earned by Mr. Hardy during the years at issue
was paid to and/or earned by him during those years. Instead,
petitioner chooses to rely on her questionable assertion that she
had no way of obtaining and presenting evidence at trial relating
11 Respondent subpoenaed Mr. Hardy as a witness at the trial in
this case. During his testimony, Mr. Hardy invoked, and the
Court sustained in certain respects, his claim under the Fifth
Amendment to the U.S. Constitution with respect to answering
certain questions concerning his employment during the years at
issue.
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