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For each of the years in issue, petitioner was a full-time
teacher. In addition to teaching, petitioner operated a store,
P&S Fashions (P&S Fashions), from a room attached to the rear of
her house. Petitioner also was involved in Eagle Marketing Inc.
(Eagle), a network market venture. Petitioner's responsibilities
for Eagle included traveling and recruiting others to become
Eagle representatives. For both 1993 and 1994, petitioner
combined her income from P&S Fashions and from Eagle and reported
it on a single Schedule C.
On July 7, 1994, the Flint River overflowed, flooding parts
of Albany, Georgia. The flood destroyed all of petitioner's
records for 1993 for both P&S Fashions and Eagle. Petitioner,
however, did retain some expense sheets for 1994, which cover 11
months of that year and detail mileage driven and amounts spent
on food and lodging during trips taken on behalf of Eagle.
During the years in issue, petitioner provided support for
Jasmine and Brandy Wilson, who lived with her. Jasmine and
Brandy Wilson attended Martin Luther King, Jr. Elementary School
which required emergency contact cards. The cards listed
petitioner as guardian for Jasmine and Brandy Wilson and
petitioner's address was listed as their home. The cards were
stored at the school. The Flint River flood, however, destroyed
many of the records of the school. Although petitioner found the
original emergency contact cards at the school, she concluded
that they were not fit for introduction to the Court. Petitioner
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