Robert Lee and Rebecca Waters - Page 7

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          At that time, First Independence, as highest bidder with an offer           
          of $50,000 at public auction, received a sheriff’s deed dated               
          June 27, 1996 (the sheriff’s deed).                                         
               The sheriff’s deed gave notice, in part, that “During the              
          six months immediately following the sale, the property may be              
               Neither petitioner nor petitioner Rebecca Waters nor                   
          petitioner’s father redeemed the Hazelwood property.                        
               In March 1997, First Independence conveyed the Hazelwood               
          property by warranty deed to an unrelated third-party.                      
          F.  Petitioners’ Income Tax Return                                          
               On May 27, 1998, respondent received petitioners’ U.S.                 
          Individual Income Tax Return, Form 1040, for 1997.  The return              
          was signed by petitioners and dated April 28, 1998.  Petitioners            
          did not apply for, or receive, any extension of time to file.               
               On their return, petitioners reported adjusted gross income            
          of $64,806.99 and taxable income of zero.  Petitioners reported             
          no tax liability and claimed a refund in the amount of the tax              
          that had been withheld from petitioner’s wages as a teacher.                
               Petitioners itemized their deductions for 1997.  In this               
          regard, petitioners attached Schedule A, Itemized Deductions, to            
          their return and claimed total itemized deductions of $311,514.             

          escrow deficiency of $1,324.                                                

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