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withheld of $7.06. Graphic Products, Inc. prepared a 1995 Form
W-2 for petitioner indicating wage income of $20,282.89 and
Federal income tax withheld of $1,745.49. Draperies and More,
Inc. prepared a 1995 Form W-2 for Mr. Tillotson indicating wage
income of $8,343.27 and Federal income tax withheld of $243.
Petitioner and Mr. Tillotson timely filed with the Internal
Revenue Service a joint Form 1040, U.S. Individual Income Tax
Return, for taxable year 1995. On their jointly filed Form 1040,
petitioner and Mr. Tillotson reported: (1) Wage income of
$34,152; (2) taxable interest income of $21; (3) taxable income
of $22,623; (4) Federal income tax withheld of $1,995; and (5) an
amount owed of $1,399. Petitioner and Mr. Tillotson did not
satisfy the underpayment when they filed their joint 1995 Federal
income tax return.
During 1997, petitioner was employed by JCPenney Life
Insurance and ODESCO. During 1997, Mr. Tillotson was employed by
Intellect Network Technologies for part of the year. Mr.
Tillotson was also self-employed during 1997. JCPenney Life
Insurance prepared a 1997 Form W-2 for petitioner indicating wage
income of $9,434.92 and Federal income tax withheld of $584.83.
ODESCO prepared a 1997 Form W-2 for petitioner indicating wage
income of $1,283 and Federal income tax withheld of $118.01.
Intellect Network Technologies prepared a 1997 Form W-2 for Mr.
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