Darlene Rose Esposito a.k.a. Amnesty International - Page 3




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                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioner resided in and                
          Amnesty was located at Rahway, New Jersey, at the time the                  
          petition in this case was filed.                                            
               Petitioner was involved in an automobile accident in which             
          she received several injuries.  As a result of her injuries                 
          petitioner was unable to work.  She applied for and began                   
          receiving in October of 1989 Social Security disability benefits            
          of $329 per month.                                                          
               At some point petitioner applied for and received an                   
          employer identification number (EIN) under the name of "Amnesty             
          International".  Later, as a result of petitioner's filing a Form           
          5500-EZ, Annual Return of One-Participant (Owners and Their                 
          Spouses) Retirement Plan, that had no EIN or an incorrect EIN,              
          the Internal Revenue Service assigned her an EIN in her name.               
               For the year 1996, petitioner filed a Form 5500-EZ using her           
          EIN, listing herself as employer, listing "Name of plan" as                 
          Social Security disability insurance, and on the attached                   
          Schedule B, Actuarial Information, listing herself as "plan                 
          sponsor" and actuary.  On the attached Schedule SSA, Annual                 
          Registration Statement Identifying Separated Participants With              
          Deferred Vested Benefits, petitioner listed the "Name of plan               
          sponsor (employer if for a single employer plan)" as Amnesty                






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