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1989 income tax liabilities. Those tax liabilities, which
include deficiencies, interest, penalties, and underpayments, are
as follows:
Year Liability
1982 $216,040.49
1983 154,412.96
1984 21,181.26
1988 2,496.38
1989 3,598.37
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition, petitioner resided in Kentfield, California.
Petitioner was born in Germany. While in Germany,
petitioner completed the equivalent of a ninth-grade education.
She has never taken any business or tax classes. Her native
language is not English.
In February 1967, petitioner married Donald K. Hopkins.
Petitioner and Mr. Hopkins were separated on February 1, 1989,
and subsequently divorced. Mr. Hopkins was an airline pilot
during the relevant periods, and he earned a substantial salary.
Petitioner did not work outside her home during her marriage.
1(...continued)
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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