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Petitioners Rogelio R. Balot (hereinafter sometimes referred
to as Rogelio) and Zenaida V. Balot (hereinafter sometimes
referred to as Zenaida) filed joint tax returns for the years in
issue, but have since divorced. Petitioners resided at separate
addresses in Fort Washington, Maryland, when they filed their
joint petition.
A. Rogelio’s Background
From 1967 to April 1989, Rogelio served in the United States
Navy as a logistician; that is, a person who is responsible for
logistics. Logisticians attend to the details of acquiring
equipment and other supplies, making sure that these supplies
meet specifications, and making sure that these supplies are sent
to the right place at the right time. During the last 3 years of
his military service, Rogelio was the enlisted supervisor of
about 25 people who dealt with logistics for the Presidential
helicopter in Quantico, Virginia. Rogelio received pension
distributions from the Navy in each of the years in issue.
In 1989, shortly after retiring from the Navy, Rogelio
obtained full-time employment as a logistician with Validity
Corporation, a defense contractor that deals with the Government.
Rogelio attended to the requisitioning of supplies for the
Validity Corporation, a task similar to his Navy duties. He did
not have any supervisory responsibilities in this Validity
Corporation position. Validity Corporation compensated Rogelio
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