Janet L. Pickering - Page 4

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          incorporated herein by this reference.2  At the time the petition           
          was filed, petitioner resided in Sterling, Virginia.                        
               During the 2000 taxable year, petitioner received the                  
          following:  (1) Wages of $1,972 from the Loudon Baptist Temple;             
          (2) interest of $1,643 from both Merrill Lynch Pierce Fenner &              
          Smith (Merrill Lynch) and Prudential Securities, Inc.                       
          (Prudential); (3) dividends of $1,561 from Merrill Lynch and                
          Prudential;3 and (4) an income tax refund of $114 from the                  
          Commonwealth of Virginia Department of Tax.                                 
               On March 9, 2000, petitioner sold 125 shares of Series A,              
          8.5 percent cumulative preferred stock in Americo (Americo stock)           
          and received sale proceeds of $2,963.  In January 1994,                     
          petitioner had purchased 560 shares of Americo stock for                    
          $13,864.50.  The sale of Americo stock thus resulted in a loss of           
          $131.75.                                                                    




               2  The stipulation of facts was filed without trial and                
          without an appearance by petitioner at a trial scheduled for May            
          12, 2004.  By Order dated May 12, 2004, we offered petitioner an            
          opportunity, if she so desired, to supplement the record by June            
          11, 2004.  During a conference call with the parties on June 22,            
          2004, we again advised petitioner of an opportunity to supplement           
          the record.  Other than the stipulation of facts and the attached           
          exhibits, the Court has not received any indication from                    
          petitioner of an intention to supplement the record.                        
               3  As indicated earlier, respondent concedes that petitioner           
          did not receive $347 in dividends, the difference between what              
          respondent determined in the notice of deficiency and the                   
          stipulated amount of $721.                                                  




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