Francis Z. Mischel - Page 4

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          B. Petitioner's Employment                                                  
               Petitioner worked for Sandia Oil Co. (Sandia) and Show Low             
          Gemstones, Inc. (Show Low) in 1992.  During that year, petitioner           
          received wages from those companies in the amounts of $5,735 and            
          $13,518, respectively, for a total of $19,253.  No Federal income           
          tax was withheld from petitioner's wages by Sandia; Federal                 
          income tax in the amount of $20 was withheld from petitioner's              
          wages by Show Low.                                                          
               Petitioner provided the sole support for herself and her               
          family in 1992.                                                             
          C. Petitioner's Form 1040A                                                  
               On April 23, 1993, respondent received a Form 1040A (U.S.              
          Individual Income Tax Return) that purported to be an income tax            
          return for 1992 (the Form 1040A).  Although the Form 1040A was              
          signed by petitioner, it was prepared by (or at the direction of)           
          Mr. Mischel.                                                                
               The Form 1040A disclosed petitioner's filing status as                 
          "head-of-household", claimed the standard deduction in the amount           
          appropriate for that filing status, and listed Andre, Daphne, and           
          Melody as dependents.  The Form 1040A also included the following           
          numerical entries:                                                          











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