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All of the above properties are located in Chelsea,
Massachusetts.
Mr. London's parents held a safe deposit box (No.
1618) at the Broadway National Bank. In June 1980, the
safe deposit box was in the name of Mr. London and his
parents as joint tenants. In 1984, the safe deposit box
was changed to another box, No. 891, and it was held
jointly by petitioners and Mr. London's mother.
Petitioner's parents filed Federal income tax returns
for taxable years 1966 through 1980. His mother filed a
Federal income tax return for the taxable year 1981, but
she did not file individual income tax returns for taxable
years 1982 through 1988. Set out below is the amount of
Federal income tax paid by petitioner's parents from 1966
through and including 1988:
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