Shuang-Di Sun Bennett - Page 4

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          house as Mr. Bennett until May 8, 2000, the date their divorce              
          became final.                                                               
               Petitioner spoke little or no English when she immigrated to           
          the United States.  Even at the time of trial petitioner had                
          somewhat limited proficiency in English.  She placed her trust in           
          and completely relied on Mr. Bennett to manage their household              
          and financial matters.  She often signed documents at the request           
          of Mr. Bennett without knowing or understanding what she was                
          signing.  During the year at issue, Mr. Bennett was employed as             
          general manager of and possibly had an ownership interest in                
          Premium Fresh Juice & Food Co. (Premium Fresh Juice).                       
               During the tax year 1998, petitioner and Mr. Bennett were              
          married and living together in California, a community property             
          State.  Petitioner and Mr. Bennett filed separate Federal income            
          tax returns for 1998, each claiming a filing status of married              
          filing separately.  Petitioner’s 1998 return provided Mr.                   
          Bennett’s name and Social Security number.  The return reported             
          gross income of $34,288 ($31,385 of taxable wages, $723 of                  
          taxable interest, and $2,180 from a taxable IRA distribution), a            
          total tax of $3,372, total payments of $624, and a tax due of               
          $2,870.1  Attached to her 1998 return was a Form W-2, Wage and              
          Tax Statement, from Columbia Cleaning Co. (Columbia Cleaning),              

               1  The tax due reflected a $122 estimated tax penalty.                 
          Petitioner claimed $8,546 in itemized deductions for the year and           
          a deduction of $2,000 for an IRA contribution.                              

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