Hugh Wilkinson and Evelyn Wilkinson - Page 4

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               6.   Whether Mrs. Wilkinson is an "innocent spouse" under               
          section 6013(e) for either of the years in issue.  We hold she is            
              Unless otherwise indicated, section references are to the                
          Internal Revenue Code applicable to the years in issue.  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 stipulations and exhibits submitted therewith are                        
          incorporated herein by this reference.  Petitioners resided in               
          Westbury, New York, when they petitioned the Court.                          
          1.  Personal Background                                                      
               Dr. Wilkinson graduated cum laude from Howard University in             
          1969 and received his medical degree from Howard University                  
          Medical School in 1973.  He became board certified as an                     
          obstetrician/gynecologist in 1981.  During the years in issue,               
          Dr. Wilkinson held three employment positions where he maintained            
          professional relationships with his colleagues and approximately             
          3,500 patients.  Primarily, he was a full-time, self-employed                
          physician specializing in obstetrics and gynecology with a                   
          medical practice located in Brooklyn, New York.  Additionally, he            
          worked part time for New York City Health & Hospitals at Kings               
          County Abortion Unit.  He also worked part time as an associate              
          director for Wykoff Heights.                                                 

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