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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time they filed their petition, petitioners
resided in Nacogdoches, Texas.
Petitioners both practice medicine. During the years in
issue, Mr. Jorgenson worked full time as an orthopedic surgeon,
while Mrs. Jorgenson practiced full time as a radiologist.
Together, petitioners reported the following amounts as
wages and partnership income from their medical practices during
the years in issue:
Petitioners’ Wages and
Partnership Income
Taxable Year From Medical Practices
1992 $982,004
1993 865,193
1994 839,715
Petitioners were raised in rural communities. Mr. Jorgenson
grew up on a 400-acre farm in Minnesota. On the Minnesota farm,
Mr. Jorgenson’s parents maintained dairy and beef cattle, hogs,
and chickens. In addition, Mr. Jorgenson’s father planted corn
and soybeans. Mr. Jorgenson’s father gave him part of the
family’s calves, which he raised and eventually sold. Mrs.
Jorgenson was born on a 750-acre ranch near Austin, Texas. On
the farm, her father raised various crops. Her father also gave
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