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herein by this reference. At the time of filing the petitions in
these cases,3 petitioners resided in Forestville, Maryland.
Petitioners were married in 1985 and were married during the
years at issue. Mr. Cotton worked as an engineer for the U.S.
Department of the Navy, where he operated boilers and chillers.
Mrs. Cotton worked as a patent clerk for the U.S. Department of
Commerce. Petitioners lived in a two-bedroom apartment in 1994
and 1995, and they moved to a five-bedroom house in 1996. Mr.
Cotton’s adjusted gross income was $37,575 in 1994 and $48,380 in
1996.
Several individuals lived in petitioners’ household between
1994 and 1996. Samuel Douglas, petitioners’ son, lived with
petitioners between 1994 and 1996. Samuel Douglas graduated high
school in 1994 or 1995. Jerome Douglas, Mrs. Cotton’s brother,
periodically stayed with petitioners between 1994 and 1996.
Jerome Douglas was ill during the period at issue. Jerome
Douglas slept at petitioners’ home on weekends in 1994.
Shirleetta Douglas,4 Mrs. Cotton’s sister, periodically stayed
3 Mr. and Mrs. Cotton each filed separate income tax
returns for the years in issue. Separate notices of deficiency
were issued to each petitioner and a separate petition was filed
by each petitioner. By order dated Apr. 10, 2000, the dockets
were consolidated.
4 Shirleetta Douglas’ first name is inconsistently
spelled throughout the record and exhibits as Sharleta, Sharletta
and Shirleetta. For consistency, we shall refer to her as
Shirleetta Douglas.
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