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she was retained as a subcontractor to clean offices. Oscar
Boldt retained petitioner to work for a second project on North
Avenue through 1993. Petitioner’s Form W-2, Wage and Tax
Statement, reflected wages of $10,754.59 and $11,413.76, for the
taxable years 1992 and 1993, respectively.
Petitioner leased a Mazda pickup truck from Fleet Services
from 1989 through 1993. Under the lease terms, petitioner was
responsible for certain specified maintenance (as defined by the
lease contract) and gasoline expenses. Mileage and other
maintenance expenses were included in the lease contract
payments.
Sometime before 1991, petitioner developed an interest in
Japanese culture. Petitioner frequented a local Japanese
restaurant and sushi bar called Izumi’s. At times, petitioner
ate both lunch and dinner, sometimes daily, at Izumi’s. Through
petitioner’s interaction with other Izumi’s patrons, petitioner
acquired a few new cleaning customers, including GE and Star
Automation. Petitioner often bought meals and gifts for her new
Japanese acquaintances. She visited Japan in 1990, 1991, and
1994 to learn more about its language and culture, and to visit
various companies for the purpose of obtaining new accounts.
Petitioner took Japanese language classes in order to communicate
with the Japanese contacts she met. Many of the Japanese
business people petitioner met did not work for companies in the
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Last modified: May 25, 2011