Gene and Ciao Newman - Page 4




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               Petitioners attached to their Forms 1040 for 1995, 1996, and           
          1997 various Forms W-2, Wage and Tax Statements, disclosing the             
          payment of wages to petitioners during the taxable years in                 
          issue.  By way of example, petitioners attached three Forms W-2             
          to their Form 1040 for 1996.  The first Form W-2 for 1996 was               
          from Leonard’s Machine Shop in Sparks, Nevada; it disclosed the             
          payment of wages to petitioner in the amount of $10,788.69 and              
          the withholding of Federal income tax in the amount of $174.29.             
          The second Form W-2 for 1996 was from Northern Nevada Tool & Die,           
          Inc. in Reno, Nevada; it disclosed the payment of wages to                  
          petitioner in the amount of $23,953.47 and the withholding of               
          Federal income tax in the amount of $692.04.  The third Form W-2            
          for 1996 was from Chemex Labs, Inc., in Sparks, Nevada; it                  
          disclosed the payment of wages to petitioner Ciao Newman in the             
          amount of $23,152.75 and the withholding of Federal income tax in           
          the amount of $516.15.                                                      
               Petitioners also attached to their Forms 1040 for 1995,                
          1996, and 1997 a typewritten statement.  The typewritten                    
          statement that petitioners attached to their Form 1040 for 1996,            
          which statement is essentially identical to the statements that             
          petitioners attached to their other Forms 1040, stated, in part,            
          as follows:                                                                 
               We are submitting this statement as part of our                        
               1996 income tax return.                                                







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