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FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated herein
by this reference.
A. Background
Petitioner resided in Beaufort, South Carolina, on the date
the petition in this case was filed.
Petitioner and her former spouse, Kenneth Washington (Mr.
Washington), were married in 1970. Petitioner and Mr. Washington
permanently separated in 1992; they were divorced in 1997. During
their marriage, petitioner and Mr. Washington had two children who
at the time of trial in this case were ages 14 and 16. Petitioner
is a high school graduate. At all relevant times, she was employed
as a Government purchasing agent with the Marine Corps Air Station.
Petitioner has been employed by the Federal Government for
approximately 20 years.
At all relevant times, Mr. Washington was a self-employed
carpenter. Mr. Washington did not discuss his business or
financial dealings with petitioner.
B. The Unpaid 1989 Tax Liability
On April 15, 1990, petitioner and Mr. Washington jointly filed
a Form 1040, U.S. Individual Income Tax Return, for 1989 (the 1989
joint return) that was prepared by a tax return preparer.
Petitioner provided her Form W-2, Wage and Income Statement, to the
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