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Mr. Martinez, who at all relevant times was an attorney, and
Ms. Martinez, his spouse, lived in Metairie, Louisiana, at the
time the petition was filed.
Petitioners refused to file tax returns (returns) and pay
tax for the years at issue because of the decision of the Supreme
Court of the United States in Roe v. Wade, 410 U.S. 113 (1973).
Petitioners' refusal to file returns and pay tax for the years at
issue is grounded in their contention that their constitutional
rights will be violated because any tax that they might pay would
be used in part to fund abortions, which is contrary to the
teachings of their religion.
Respondent issued separate notices of deficiency (notices)
to Mr. Martinez and to Ms. Martinez for 1982, 1983, and 1984 and
separate notices to them for 1985, 1986, and 1987. In the
notices, respondent determined that, for the years at issue, each
petitioner had one or more of the following types of community
income/loss: Capital gain/loss, interest income, rental in-
come/loss, employee compensation, nonemployee compensation,
partnership income/loss, dividend income, Schedule C net income,
and/or miscellaneous income.2 Respondent also determined that,
for the years at issue, each petitioner is entitled to itemized
deductions for certain community expenses and to a deduction for
2 In the absence of adequate records for 1984, respondent
determined each petitioner's miscellaneous community income for
that year by reference to bank deposits, cash payments, and
personal and other nondeductible expenditures.
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