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FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
herein by this reference. When she petitioned this Court,
petitioner resided in Blacksburg, Virginia, with her husband, Dr.
Salvatore D. Barranco (Dr. Barranco).
I. Personal History/Household Management
Petitioner and Dr. Barranco were married during all the
years at issue, as well as up through the trial of this case.
They have three daughters and a son.
When petitioner married Dr. Barranco in 1961, she was in her
second year of nursing school; he was in medical school. Since
getting married, she has not received other formal education or
gainfully worked outside the home.
During the years at issue, Dr. Barranco was a financially
successful orthopedic surgeon in private practice in Blacksburg,
Virginia. In 1983, he was a 50-percent shareholder of the
medical practice corporation in which he practiced. During the
remaining years at issue, he was the sole shareholder of the
corporation. Petitioner was not involved in Dr. Barranco’s
medical practice, and he did not usually discuss it with her.
1(...continued)
otherwise indicated, all other section references are to the
Internal Revenue Code in effect for the years at issue and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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