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education programs and administering oaths of office of public
officials.
In 1992, petitioner ran for reelection as a Justice of the
Mississippi Supreme Court and was defeated. Petitioner resigned
from the court on August 31, 1992, and began teaching at Fordham
University School of Law in New York in September 1992 as a
visiting professor. In January 1993, petitioner returned to
Jackson, Mississippi, and entered private practice.
Federal Income Tax Returns
For each of the years in issue, petitioners filed a joint
Federal tax return. Petitioners reported adjusted gross income of
$110,841.08 for 1990, $113,362.55 for 1991, and $138,690 for 1992.
Petitioner's wage and salary income (before retirement
contributions) for the years in issue was as follows:
1990 1991 1992
Supreme Court $75,000 $75,195 $49,988
Univ. of Miss. 15,000 14,642 7,483
Fordham Univ. --- --- 49,185
Total 90,000 89,837 106,656
Petitioner was reimbursed by the State of Mississippi for
travel, lodging, and meal expenses incurred while attending
Mississippi Supreme Court sessions in Jackson and returning to
Oxford. At the end of each month, petitioner prepared a schedule
of expenses and submitted them to the financial officer of the
court for reimbursement, and a check would be issued in that amount
to petitioner within 8 to 10 days. Petitioners did not report the
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