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enrollment, or profit from excess enrollment, rested with the
universities; (3) petitioner began his relationship with the
universities in 1991, and he has continued to teach various
courses related to his profession at both universities; and
(4) each written contract expressly provides that petitioner
would be treated as an employee.
Accordingly, we find that petitioner was an employee of ISU
and UOI during 1997. It follows that expenses related to his
teaching activities must be deducted as miscellaneous itemized
deductions. See secs. 62(a)(1), 63(d), 67(a). Respondent’s
determination in this regard is therefore sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Based on the foregoing,
Decision will be
entered for respondent.
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