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Each of petitioners' returns describes the occupation
of both Mr. and Mrs. London as "manager". Mrs. London
received Forms W-2, Wage and Tax Statement, from London's
Cafe, Inc., and M.L. Associates reporting the following
wages:
Year London's Cafe, Inc. M.L. Associates
1976 $2,650 --
1977 2,600 --
1978 2,600 --
1979 -- --
1980 2,600 --
1981 2,600 --
1982 2,650 --
1983 2,600 $1,920
1984 2,600 2,080
1985 2,600 3,900
Petitioners' returns also report individual retire-
ment account contributions on behalf of Mrs. London in the
amount of $390 for each year 1976 through and including
1981, and in the amount of $2,000 for 1982 through and
including 1985. We note that petitioners' return for 1977
includes Form 5329, Return for Individual Retirement
Savings Arrangement, on behalf of Mrs. London, on which
"No" is checked in response to the question "Are you a non-
working spouse for whom this arrangement has been
established?" We also note that petitioners' returns for
1982 through and including 1985 include Schedule W,
Deduction for a Married Couple When Both Work, on which
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