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the District of Columbia school system for 20 years, as a teacher
and a counselor. Additionally, for 38 years, she operated a
beauty salon, which employed one other person, who tended the
salon while petitioner was working at the school. Petitioner did
not maintain the beauty salon’s books or payroll personally;
instead, she engaged others to do so.
At the time of his death, Mr. Mitchell was a teacher and the
Director of Federal Programs for the Charles County, Maryland,
Board of Education. Mr. Mitchell managed the family’s finances.
He made the decisions with respect to major purchases and
investments, paid the bills, and engaged an adviser to help him
prepare the tax returns.
At the beginning of 1991, petitioner and Mr. Mitchell had
three children in college and a fourth living at home. They were
paying tuition and other expenses of the children in college.
They were barely able to pay the family’s bills. Their house was
in need of substantial repairs.
Mr. Mitchell had been a member of the Teachers’ Retirement
System of the State of Maryland (Retirement System) until he
transferred to the Teachers’ Pension System (Pension System).
The Retirement System is a qualified defined benefit plan under
section 401(a) requiring mandatory nondeductible employee
contributions, and the trust maintained as a part of the plan is
exempt from taxes under section 501(a). The State of Maryland
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