Sarah A. Bland-Barclay and Francis Barclay - Page 3

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          Maryland.2  During the year in issue, Sarah A. Bland-Barclay                
          (petitioner) and Francis Barclay (Mr. Barclay), were husband and            
               During 1996, Mr. Barclay was a welder for the General Motors           
          Corp. at its Truck & Bus Group assembly plant in Baltimore.  Also           
          in 1996, petitioner began a career as a tax preparer at Jackson             
          Hewitt Tax Service after completing a 6- to 8-week tax training             
          program.  In further pursuit of her career, petitioner enrolled             
          in a 2-year associate’s degree program at Essex Community                   
          College, majoring in accounting.  Petitioner has not completed              
          this program due to, in part, Mr. Barclay’s death in 1998.                  
          Petitioner, in addition to her job as a tax preparer, had other             
          part-time employment.                                                       
               Petitioner and Mr. Barclay timely filed their joint 1996               
          Federal income tax return electronically, which was prepared by             
          Barclay’s Tax Service, a business operated by petitioner.  On               
          June 24, 1998, during their examination of their 1996 income tax            
          return, they submitted to respondent an amended 1996 Federal                
          income tax return, Form 1040X, Amended U.S. Individual Tax                  
          Return, which had not been filed.                                           
               On their 1996 income tax return, petitioner and Mr. Barclay            
          reported $86,282 of wages from the following sources:                       

          2    Francis Barclay died intestate in December 1998.  Petitioner           
          Sarah A. Bland-Barclay was issued letters of administration by              
          the Orphans Court of Baltimore City.                                        

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