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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioner Sarah K. Hawthorne (Hawthorne) lived in Burnet,
Texas, when she filed her petition. Petitioner Fredie Lynn
Charlton (Charlton) lived in Buchanan Dam, Texas, when he filed
his petition. Petitioners lived in Texas, a community property
State, at all times relevant to this case.
Hawthorne has a college degree in English. She completed an
accounting class and a marketing class but she did not do well in
them. Hawthorne did not take any income tax courses.
Petitioners were married in 1989. Before they were married,
Charlton hired Hawthorne to be an office manager for a large
manufacturing business.
Charlton was employed full time in Houston, Texas, until
September 1994. He moved his residence to Buchanan Dam, Texas,
in the fall of 1994.
B. Medi-Task
Medi-Task was a physician’s transcription service.
Hawthorne managed Medi-Task and performed most of its day-to-day
operations. Medi-Task had one employee in 1994. Independent
contractors did most of the transcribing for Medi-Task. Charlton
did not devote much time to Medi-Task because he was employed
full time until September 1994. He was not involved with Medi-
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