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All section references are to the Internal Revenue Code as in
effect for the years under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated herein
by this reference.
Petitioners were married in December 1971 and divorced in
October 1986. They timely filed joint Federal income tax returns
for 1980, 1981, 1982, 1983, and 1984, the years under
consideration. They resided in Escondido, California, at the time
the petition in this case was filed.
Mrs. Pewitt (hereinafter sometimes referred to as petitioner)
has a high school education; she did not attend college. Upon
graduating from high school in 1967, she worked as a dental
assistant. She married Dennis Pewitt (Mr. Pewitt) when she was 22
years of age. She continued working as a dental assistant for 4
years following her marriage and then attended John Mycut School of
Real Estate, where she obtained a real estate license. Thereafter,
she sold residential real estate for approximately 2 years. She
stopped working when she had her first child in 1978.
Mr. Pewitt's education was similar to that of Mrs. Pewitt
except he took several courses at Everett Community College. He
began employment as a dispatcher for the police department, where
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