Charol L. Stafford - Page 3

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          failed to report her 50-percent share of community property                 
          income earned by Mr. Stafford in his individual capacity for                
          those years; (2) Mrs. Stafford failed to file Federal income tax            
          returns for 1991 and 1992 and thus failed to report her 50-                 
          percent share of community property income earned by Mr. Stafford           
          in his individual capacity for those years; and (3) Mr. Stafford            
          failed to file Federal income tax returns for any year at issue             
          and thus failed to report his 50-percent share of community                 
          property income earned by petitioners in their individual                   
          capacities.                                                                 
               Respondent determined that Mrs. Stafford received the                  
          following wage income:                                                      
          Year                   Payor                      Amount                    
          1989           North Forest Independent                                     
                         School District                    $  3,670                  
                         Molly Maid of Champions       421                            
          1990           North Forest Independent                                     
                         School District                    10,875                    
          1993           Tarkington Independent                                       
                         School District                    6,769                     

               Respondent determined that Mr. Stafford received the                   
          following wage and pension income:                                          
          Year                 Payor                        Amount                    
          1989           BP Exploration                     $44,763                   
          1990           BP Exploration                     30,572                    
                         BP Exploration                                               
                         (1099-R pension income)            39,073                    
                         Carlton Accountants                6,362                     
                         Texas Employment Comm'n            4,774                     
          1991           Carlton Accountants                6,289                     
                         Accountants on Call                31,280                    
          1992           Accountants on Call                53,600                    
          1993           Accountants on Call                27,060                    




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