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Section references are to the Internal Revenue Code in
effect for the applicable years.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Coral Springs, Florida, when she filed
her petition. Since October 19, 1952, petitioner has been
married to Albert Ferrarese (Ferrarese).
Petitioner’s and Ferrarese’s checking account balance was
$119.76 on June 22, 2000, $782.53 on July 20, 2000, $315.84 on
August 22, 2000, and $140.78 on September 20, 2000. At the time
of trial, petitioner was 68, Ferrarese was 77 and was suffering
from congestive heart failure, and their only sources of income
were monthly Social Security payments of about $430 to petitioner
and $1,110 to Ferrarese. At that time petitioner’s and
Ferrarese’s expenses exceeded their income, and petitioner’s and
Ferrarese’s children were providing money to them to pay some of
their living expenses. At the time of trial, petitioner and
Ferrarese owned a 1998 Ford Taurus and lived in a condominium in
Florida owned solely by petitioner, the assessed value of which
for county real property tax purposes was between $40,000 and
$50,000.
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