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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
not.
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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