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Petitioner is a high school graduate. Petitioner also
attended college but did not graduate from college. She and Mark
C. Christman (Mr. Christman) married on October 24, 1992, and had
one son. Petitioner moved out of the marital home sometime in
mid-to-late 1999 and opened separate bank accounts in her name.
She and Mr. Christman divorced on October 6, 2000.
Petitioner earned income during taxable years 1998 and 1999
from her employment with The Bon-Ton Stores, Inc.; Brooks
Brothers, Inc.; Eugene Davids Co., Inc.; Tutor Time; and York
Beauty Supply & Equipment Co., Inc. During the same years, Mr.
Christman was employed by local architects. Additionally, he
earned income as a draftsman for Draft Tech, Inc., a business he
wholly owned, the income and expenses of which were reported on
Schedule C, Profit or Loss From Business, on their joint income
tax returns for the years at issue.
In 2000, Mr. Christman approached petitioner on different
occasions to obtain her signature on the joint income tax returns
for 1996, 1997, 1998, and 1999. On July 7, 2000, petitioner and
Mr. Christman filed a joint return for 1998 reporting a tax
liability of $7,744. A payment of $744 was submitted with the
return. No notice of deficiency was issued by respondent for
taxable year 1998. Additions to tax were thereafter assessed for
1998 under sections 6651(a)(1) and (2) and 6654.
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