Ruth E. Neal - Page 2

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                                   Year     Amount                                      
                                   1993     $52,689                                     
                                   1994     31,191                                      
                                   1995     20,039                                      

               Unless otherwise indicated, all section references are to                
          the Internal Revenue Code in effect for the years in issue, and               
          all Rule references are to the Tax Court Rules of Practice and                
          Procedure.                                                                    

                                   FINDINGS OF FACT                                     
               Some of the facts have been stipulated and are so found.                 
               At the time the petition was filed, petitioner resided in                
          Evans, Georgia.                                                               
               In the late 1960s, petitioner graduated with a B.S. in                   
          chemistry from Xavier University located in New Orleans,                      
          Louisiana.  In May of 1973, petitioner graduated with a medical               
          degree from Howard University College of Medicine, located in                 
          Washington, D.C.                                                              
               After graduating from medical school, petitioner completed a             
          1-year internship and a 3-year radiology residency also at Howard             
          University Hospital.                                                          
               On January 3, 1976, petitioner and Alimam Neal (Alimam) were             
          married.  At the time of their marriage, petitioner was 27 and                
          Alimam was 28 years old.  This marriage was petitioner's first                
          and Alimam's second.                                                          







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