Susan E. Shores - Page 2

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               The only issue for decision is whether petitioner is                   
          entitled to deduct certain business expenses, which she claimed             
          on Schedule C of her 1994 return, in excess of the amounts                  
          allowed by respondent.2                                                     
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated herein by this reference.  At the time of filing the           
          petition, petitioner resided at Palo Alto, California.  For                 
          clarity and convenience, we have combined the findings of fact              
          and discussion of pertinent legal issues.                                   
               In March 1990, petitioner entered into an agreement with a             
          company named Au Pair In America (hereinafter APIA).  The                   
          agreement was titled "Community Counselor Letter of Agreement"              
          and provided in part that                                                   
               The Community Counselor interviews potential Host                      
               Families to evaluate their appropriateness for the                     
               [APIA] Program, matches Host Families with Au Pairs,                   
               has responsibility for a cluster of area Au Pairs                      
               throughout the year's exchange and generally                           
               facilitates the Host Family/Au Pair relationship.                      


               2   Respondent's notice of deficiency also reduced                     
          petitioner's total itemized deductions from $13,219 to $11,056              
          and increased petitioner's self-employment tax from $376 to                 
          $1,219. The parties appear to agree that these adjustments are              
          dependent upon the other adjustments, and therefore, we do not              
          separately address them.  To the extent that petitioner seeks an            
          abatement of interest (or review thereof), she must make such a             
          request to the Commissioner and await a final determination not             
          to abate interest.  Sec. 6404(g); see Bourekis v. Commissioner,             
          110 T.C. 20, 27 (1998).                                                     




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