Mung Thi Huynh - Page 3

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          time late in 1992 or early in 1993, Mr. Juarez left petitioner’s            
          employ, and he became associated with her again in approximately            
          March 1993.                                                                 
               When Mr. Juarez became reassociated with petitioner, they              
          entered into an arrangement under which Mr. Juarez would act as             
          some form of intermediary between petitioner and the customer or            
          consumer of the manufactured piecework.  Mr. Juarez operated                
          under this arrangement beginning around March 22, 1993, using the           
          name “Lemarant Fashion’s”.  The documents offered by petitioner             
          in an attempt to show that this type of arrangement existed in              
          1992, had been falsified by changing the year from 1993 to 1992.            
                              ULTIMATE FINDING OF FACT                                
               Petitioner failed to show that she is entitled to deduct any           
          part of the $459,650 that she claimed as commissions and fees,              
          which were disallowed by respondent.                                        
                                       OPINION                                        
               This case presents a clearly defined factual question.                 
          Respondent disallowed $459,650 that petitioner had claimed as               
          commissions and fees on her 1992 Schedule C.  Petitioner, in                
          support of her position that she is entitled to deduct the                  
          questioned amount, testified that Mr. Juarez was paid the amount            
          as an intermediary between herself and the customer.  Petitioner            
          also offered a purchase order book reflecting 1992 transactions             
          with Mr. Juarez.                                                            





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