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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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Last modified: May 25, 2011