Cindee J. Conner - Page 3




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          the year in issue, and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            
               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the taxable year 1997 in the amount of $11,344.              
          The issues for decision are:  (1) Whether respondent is barred by           
          the statute of limitations from assessing and collecting the                
          deficiency (this issue turns on the question of whether                     
          petitioner filed an income tax return for 1997); (2) whether                
          petitioner failed to report wage income earned in 1997 in the               
          amount of $33,711; (3) whether petitioner failed to report income           
          from a long-term capital gain in the amount of $45,023, arising             
          from a deed in lieu of a foreclosure transaction; (4) whether               
          petitioner is entitled to innocent spouse relief; and (5) whether           
          petitioner is liable for additions to tax pursuant to sections              
          6651(a)(1)1 and 6654.                                                       
                                     Background                                       
               The stipulation of facts and the attached exhibits are                 
          incorporated herein by reference.  At the time the petition was             
          filed, petitioner resided in McHenry, Illinois.                             
               Petitioner and James Conner (Mr. Conner) were married on               
          July 13, 1974.  Two children were born of the marriage.  The                
          couple purchased a home in Barrington, Illinois, in May 1987, for           


               1 At trial, respondent conceded the addition to tax under              
          sec. 6651(a)(2); therefore that addition is no longer an issue              
          before us.                                                                  





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