Gwendolyn A. Ewing - Page 5

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          decreased dramatically.  Since 1997, petitioner has worked at               
          several temporary jobs and paid all of her and about 80 percent             
          of Mr. Wiwi’s expenses.  Petitioner’s total monthly household               
          expenses on behalf of herself and Mr. Wiwi in 1997 and 1998                 
          (including rent, utilities, transportation, food, clothing, and             
          medical insurance) were about $2,800.                                       
               Petitioner had about $5,000 in her savings account in 1996             
          and $13,500 at the time of trial.  She received wages of $65,792            
          in 1997, $65,338 in 1998, $66,315 in 2000, and $79,000 in 2002.2            
               Mr. Wiwi’s medical condition worsened, which prevented him             
          from working in 2000.  He had hip replacement surgery in 2000 and           
          2001.                                                                       
               In 2000, petitioner liquidated an individual retirement                
          account (IRA) and used the proceeds (about $20,000) as part of a            
          $33,000 downpayment to buy a $333,000 residence for Mr. Wiwi and            
          herself.  The monthly mortgage payment was about the same as                
          their previous rent payments.  At the time of trial, petitioner             
          had a section 401(k) retirement account with the American Red               
          Cross.  The record does not indicate the value of that account.             
          B.   Petitioner’s Request for Relief From Joint Tax Liability               
               On February 2, 1999, petitioner filed Form 8857, Request for           
          Innocent Spouse Relief (And Separation of Liability and Equitable           
          Relief), in which she sought relief from joint liability for a              


               2 The record does not indicate the amount of petitioner’s              
          income for 1999 and 2001.                                                   



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