Susan E. Shores - Page 4

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          APIA, and she used a room in her home exclusively as an office              
          for this purpose.                                                           
               Petitioner's 1994 Schedule C reflects "consultant" as her              
          principal business activity and "Au Pair in America" as the                 
          business name.3  Shirley Gaman prepared petitioner's 1994 income            
          tax return.  Petitioner gave Ms. Gaman her "checks and credit               
          card things, and receipts" and paid Ms. Gaman $200 for her                  
          services.  Ms. Gaman did not execute the return as preparer.  Ms.           
          Gaman died at some point after preparation of the return.                   
               Petitioner reported income and claimed expenses relating to            
          her "consultant" business during the year in issue as follows:              
          Income:                                                                     
          Gross receipts                          $17,260.00                          
          Expenses:                                                                   
          Advertising                        $830.16                                  
          Car and truck expenses             2,600.24                                 
          Legal and professional services     300.00                                  
          Rent or lease:                                                              
          Vehicles                 480.32                                             
          Other business property          1,750.00                                   
          Repairs and maintenance            598.17                                   
          Supplies                           1,429.28                                 
          Travel, meals, and entertainment:                                           
          Travel                        1,940.00                                      
          Meals and entertainment       261.81                                        
          Utilities                           1,742.80                                
          Total expenses                                      11,932.78               
          Net (profit)                            5,327.22                            
          Petitioner also reported wages from employment unrelated to the             
          Schedule C activity in the amount of $41,859.49.                            

               3  Respondent does not dispute that petitioner was self-               
          employed as a "consultant" for Au Pair In America.                          




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