Evelyn J. Glenn - Page 4




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                7. Whether petitioner is liable for accuracy-related                  
           penalties for 1995 and 1996.  We hold that she is.                         
                Adjustments in the notice of deficiency relating to the               
           self-employment tax, the related deduction under section                   
           164(f), the deductible amount of petitioner’s medical expenses,            
           and the earned income credit are purely mechanical matters, the            
           resolution of which is dependent on our disposition of the                 
           disputed issues.                                                           
           Background                                                                 
                Some of the facts have been stipulated, and they are so               
           found.                                                                     
                Petitioner resided in Ponte Vedra Beach, Florida, at the              
           time that her petition was filed with the Court.                           
                During the years in issue, petitioner was a self-employed             
           marketing consultant.  Petitioner offered advertising and                  
           marketing services to a clientele consisting principally, if               
           not exclusively, of medical doctors.                                       
                During 1995, petitioner’s principal client was Dr. Elliott            
           Jacobs (Dr. Jacobs), a plastic surgeon in New York City.                   
           During 1996, Dr. Jacobs was petitioner’s only client.                      
                Petitioner publicized and promoted Dr. Jacobs’ medical                
           practice by, among other ways, placing periodic advertisements             
           in the New York Post.  Dr. Jacobs compensated petitioner for               
           her services, and he reimbursed her for the cost of the                    






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