Michael London - Page 3

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               return for 1985; and (7) whether Mrs. London qualifies as a                              
               so-called "innocent spouse".                                                             
                                          FINDINGS OF FACT                                              
                      Some of the facts have been stipulated and are so                                 
               found.  The stipulation of facts, supplemental stipulation                               
               of facts, and attached exhibits are incorporated herein by                               
               this reference.  Petitioners are husband and wife.  They                                 
               filed a joint Federal income tax return for each of the                                  
               years in issue.  Respondent issued a separate notice of                                  
               deficiency to each petitioner, and each petitioner filed                                 
               a petition for redetermination in this Court.  The two                                   
               cases were consolidated pursuant to Rule 141(a), Tax Court                               
               Rules of Practice and Procedure.  In this opinion, all                                   
               Rule references are to the Tax Court Rules of Practice                                   
               and Procedure.  At the time they filed their petitions,                                  
               Mr. London resided in Lewisburg, Pennsylvania, and                                       
               Mrs. London resided in Weston, Massachusetts.  In this                                   
               opinion, we sometimes refer to Mr. London as petitioner.                                 
                      Mr. London graduated from high school in 1957.  From                              
               1957 to 1962, he attended Bordentown Military Academy, the                               
               University of Maryland, and Boston University, but he did                                
               not graduate from any of those institutions.  Mrs. London                                
               received a bachelor of arts degree from Emmanuel College                                 
               where she majored in biology.  She also received a teaching                              
               certificate from Salem State College.  After graduating                                  

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