Patricia G. McCulley - Page 3

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          against petitioner of $13,599 for 1984 and $11,358 for 1985.  In            
          determining the deficiencies for the taxable years in issue,                
          respondent made adjustments for the following items:  Unreported            
          rental income, embezzlement income, and improper real estate tax            
          and mortgage interest deductions.                                           
               Petitioner was raised in a poor neighborhood in Memphis,               
          Tennessee, in a low-income family.  At the age of 16, she married           
          her first husband, Charles Edward McCulley (McCulley).  The next            
          year petitioner became pregnant and dropped out of high school.             
          Petitioner's daughter and son were born in June of 1973, and July           
          of 1975, respectively.  In October of 1977, petitioner and                  
          McCulley were divorced.                                                     
               In 1983, petitioner completed the requirements for a general           
          equivalency diploma (GED), the highest degree she has attained.             
          In 1984, petitioner took courses as a non-matriculated student at           
          Memphis State University for which she received an A, a B, and              
          two failing grades.  Petitioner has had no education or training            
          in business or tax matters.                                                 
               During the years in issue, petitioner became involved in a             
          relationship with Byron Kelly Griffith (Griffith), a man she                
          married in 1985.  Griffith physically, mentally, and emotionally            
          abused petitioner.  During their separation a neighbor once                 
          called police, who arrested Griffith when they caught him choking           

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