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the Court that she had no evidence to present and no additional
arguments to add to those presented in her response to
respondent’s motion for summary judgment.
FINDINGS OF FACT
Petitioner and her husband filed their 1994 joint Federal
income tax return on April 15, 1995, wherein petitioner’s
occupation was shown as “registered nurse”. Attached to the
return were Forms W-2, Wage and Tax Statement, and a Form 1099-R,
Distributions From Pensions Annuities, Retirement or Profit-
Sharing Plans, IRAs, Insurance Contracts, etc., reflecting a
total of $90,017.59 for wages and income payments to petitioner
for the 1994 tax year. Petitioner and her husband reported total
joint wages of $105,265. The 1994 joint return contained a
$42,883 claimed loss on Schedule C, Profit or Loss From Business;
a $3,000 capital loss on Schedule D, Capital Gains and Losses; a
$12,821 loss on Schedule E, Supplemental Income and Loss; and
$57,768 of itemized deductions on Schedule A, Itemized
Deductions, resulting in no reported taxable income. A refund of
$12,067 was claimed, representing a claim for all of the income
tax withheld and excess employment taxes.
Petitioner’s 1994 return reflected her address as 1500 Adams
Avenue, Apt. 105, Costa Mesa, CA 92626 (Adams Avenue address).
During 1998, respondent was in communication with petitioner and
was provided with a second address--P.O. Box 11774, Costa Mesa,
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