Danielle L. Clark-Hernandez - Page 7




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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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