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petitioner's brother-in-law, John Genck, who is the band's
drummer, composer, and technical expert. The band also has a
full-time keyboard player, Jim Gazier, and various part-time
accompanying musicians who do not share in the band's profits.
The band performs at weddings and nightclubs at various locations
in the tricounty area of Dade County, Broward County, and Palm
Beach County, Florida.
Petitioner and Matthew reside in an apartment located above
a marketplace at 2424 Hollywood Boulevard in Hollywood, Florida.
The apartment is divided, in roughly equal areas, into living
quarters and an office. The two areas are connected by a single
door. The living quarters consist of two bedrooms, a living
room, a kitchen, and a bathroom. The office consists of a large
studio and a smaller room located adjacent thereto. The studio
contains recording equipment and computers. It also contains
filing cabinets in which the band's contracts, sheet music, and
supplies are stored. The smaller room contains a desk, a
telephone, a couch, and a kitchenette. Unlike the band's other
expenses, since the office is part of petitioner and Matthew's
apartment, they each paid and claimed deductions for 50 percent
of the band's office-related expenses for 1992.
Petitioner spends an average of 30 hours per week managing
the band out of the office. She promotes the band through the
distribution of advertising flyers which are designed on the
office computers. She books the band's performances and
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