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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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