Robert Cotton, Jr. - Page 4




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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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