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FINDINGS OF FACT3
Petitioner is incarcerated in a Federal penitentiary for
turning over state secrets to a foreign government at a time when
he held a position with the Central Intelligence Agency (CIA) of
the United States. He had his legal residence in Allenwood,
Pennsylvania, at the time the petition in this case was filed.
Petitioner’s employment with the CIA spanned the years 1962 to
1994, during which he was assigned to progressively more
responsible positions involving the Union of Soviet Socialist
Republics (Soviet Union) and Soviet Bloc Eastern European
countries. Throughout that time, petitioner held a Top Secret
security clearance, and he had access to information and
documents classified Secret and Top Secret.
Petitioner timely filed joint Federal income tax returns
with his wife, Rosario C. Ames, for the taxable years 1989, 1990,
1991, and 1992. Petitioner’s returns were filed on the cash
basis for reporting income and deductions. The returns primarily
reflected income from petitioner’s CIA employment in the amounts
of $70,337, $60,340, $62,514, and $67,578 for 1989, 1990, 1991,
and 1992, respectively.
In 1984, as part of his duties as a CIA Operations officer,
petitioner began meeting with officials of the Soviet Union’s
3 The stipulation of facts and the attached exhibits are
incorporated by this reference.
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