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FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
At the time of the filing of their petition, petitioners
resided in Greenwich, Connecticut. Allen C. Chamberlin
(petitioner) is a doctor of orthopedic medicine, having graduated
from the Boston University School of Medicine. Petitioners filed
their joint Forms 1040, U.S. Individual Income Tax Return, for
1982 through 1993 on the following dates:
Year Filing Date
1982 07/11/84
1983 09/06/94
1984 09/06/94
1985 09/17/88
1986 09/17/88
1987 09/17/88
1988 04/17/95
1989 04/04/95
1990 04/17/95
1991 03/27/95
1992 03/27/95
1993 10/16/95
The initial 1985, 1986, and 1987 Forms 1040 were blank and
contained no financial information. Subsequently, on
December 28, 1994, petitioners filed completed Forms 1040 for
these years. Petitioners reported $1,324, $11,264, $98, $521,
$1,584, $7,849, $9,499, $10,450, and $11,057 of total tax on
their returns for 1985, 1986, 1987, 1988, 1989, 1990, 1991, 1992,
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