Daniel F. Layman, III - Page 4




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          any time prior to December 31, 1993.  Petitioner and Peggy Layman           
          were divorced in taxable year 1994.2                                        
               During the calendar years 1991, 1992, and 1993, petitioner             
          was a resident of Phoenix, Arizona.  Arizona is a community                 
          property state.  Peggy Layman was never a resident of Arizona in            
          the calendar years 1991, 1992, or 1993.  Peggy Layman was a                 
          resident of Bailey, Colorado, during calendar year 1991, and from           
          January through July 1992.  From August 1992 through December               
          1993, Peggy Layman was a resident of Grafton, West Virginia.                
          Colorado and West Virginia are not community property states.               
               During the calendar year 1991, petitioner received taxable             
          wages in the amount of $25,380 from GTE Health Systems, Inc.                
          Petitioner also received taxable wages in the amount of $9,855              
          from Mark F. Johnson, Inc. during 1991.  During the calendar year           
          1992, petitioner received taxable wages in the amount of $60,414            
          from GTE Health Systems, Inc.  During the calendar year 1993,               
          petitioner received taxable wages in the amount of $18,202 from             
          GTE Health Systems, Inc., and taxable unemployment compensation             
          in the amount of $4,810.  Petitioner did not inform Peggy Layman            


               2We note that both petitioner and Peggy Layman filed for               
          divorce in 1994, and that the record contains two separate                  
          dissolutions of marriage.  On Sept. 20, 1994, the marriage was              
          dissolved in civil action number DR 94-06121 in the Superior                
          Court of the State of Arizona, in and for the County of Maricopa.           
          On Sept. 26, 1994, the marriage was dissolved in civil action               
          number 94-D-56 in the Circuit Court of Taylor County, West                  
          Virginia.                                                                   




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