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Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue.
Petitioner denies that she is liable for income tax or additions
to tax on her earnings as a salaried employee in private
industry.
FINDINGS OF FACT
Petitioner resided in Sugar Land, Texas, at the time that
her petition was filed. Prior to and during the years in issue,
petitioner was married to Kenneth E. Rogers. Prior to and during
the years in issue, petitioner was employed by various private
employers as a systems analyst. She received income from her
employment in the amounts of $97,156 in 1994, $85,386 in 1995,
$87,968 in 1996, and a total of $117,095 (from two employers) in
1997. During the years in issue, petitioner also received other
income from dividends, interest, and proceeds from the sale of
stock.
Prior to 1994, petitioner filed Federal income tax returns.
For 1994, she submitted to the Internal Revenue Service (IRS) a
Form 1040, U.S. Individual Income Tax Return, that reported her
income for that year, checked her status as “married filing
separate return”, and attached a statement disclaiming any tax
liability for 1994 and asserting that she “did not engage in any
licensed occupation or activity subject to an excise tax”.
Petitioner did not file an income tax return for 1995, 1996, or
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