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abused respondent’s discretion in denying petitioner relief under
that section for that year. We hold that respondent did not
abuse respondent’s discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Las Vegas, Nevada, at the time she
filed the petition.
Petitioner is a high school graduate and has completed
approximately 1-1/2 years of college at Lorain Community College
and Columbus State. During the year at issue, petitioner worked
full-time for BMW Financial Services and part-time for Dairy
Queen. On October 31, 1993, petitioner married Roger L. Castle
(Mr. Castle). At the time of the trial in this case, petitioner
worked for Continental Airlines as a flight attendant.
On August 17, 1994, petitioner and Mr. Castle signed Form
1040, U.S. Individual Income Tax Return (return), for their
taxable year 1993 (1993 joint return).2 On that date, John Obrig
signed the 1993 joint return as the paid preparer of that return.
The 1993 joint return showed, inter alia, wages totaling $25,625
received by petitioner from Adia Services, Inc. of Ohio and Banc
One Vehicle Finance Corp., income from Mr. Castle’s Schedule C
computer consulting business of $67,849, Federal income tax (tax)
2At a time not disclosed by the record, petitioner and Mr.
Castle applied for and received an automatic extension of time
until Aug. 15, 1994, within which to file the 1993 joint return.
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