Eleanor Simon - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner resided in Greensboro, North Carolina, at the               
          time she filed the petition.                                                
               Petitioner and Javester Simon (Mr. Simon), both college                
          graduates, married on or about May 20, 1966, separated on or                
          about March 5, 1999, and divorced on June 25, 2001.  The judgment           
          of divorce granting petitioner and Mr. Simon a divorce did not              
          impose any obligation on petitioner or Mr. Simon to pay any                 
          outstanding Federal income or other tax liabilities.  Nor is                
          there any other document relating to that divorce, such as a                
          property settlement, that imposed any legal obligation on peti-             
          tioner or Mr. Simon to pay any such liabilities.  Although                  
          petitioner and Mr. Simon divorced in June 2001, division of the             
          marital assets remains to be adjudicated by the North Carolina              
               During 1998, the year at issue, petitioner worked for                  
          Guilford Technical Community College (Guilford College), and Mr.            
          Simon worked for Roadway Express, Inc. (Roadway Express).  During           
          that year, petitioner and Mr. Simon received wages of $34,681.20            
          and $58,016.49, respectively.                                               
               Petitioner and Mr. Simon signed on April 15, 1999, and filed           
          the signature form of Form 1040PC Format, U.S. Individual Income            

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