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Petitioner thereafter filed an amended petition to assert her
claim for relief under section 6015.
Mr. Gurr had a tenth-grade education. Throughout their
marriage, he was self-employed. For several years, he operated a
coal business, wherein he purchased and delivered coal to
customers. At one time, he and petitioner operated a commercial
horse riding stable. Petitioner assisted in the operation of
this business. Later, Mr. Gurr went into the real estate
business, wherein he purchased and held land, either for resale
or development. This was the activity Mr. Gurr was engaged in
during the years at issue. That activity was the principal
source of income of petitioner and Mr. Gurr during 1992 and 1993.
At the time of trial, Mr. Gurr was 77 years of age, and both he
and petitioner had been retired for several years.
Petitioner was a high school graduate and attended Brigham
Young University for a short time. She did not receive a degree
from that institution. During World War II, petitioner served 2
years in the women's branch of the U.S. Navy which, at that time,
was known as the WAVES. Other than assisting in the operation of
the riding stable business, she was never employed outside the
home during her marriage with Mr. Gurr.
Petitioners filed joint Federal income tax returns for 1992
and 1993. For each year, the income and expenses from Mr. Gurr's
real estate activity were reported on Schedule C, Profit or Loss
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