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newspaper advertisements. Petitioner received the following
amounts from Dr. Jacobs in 1995 and 1996:
1995 1996
Services rendered $54,500 $40,750
Reimbursement 61,004 75,120
Total received 115,504 115,870
In 1995, petitioner had a second client, Dr. Socha, an
ophthalmologist, who also practiced in New York. Dr. Socha
paid petitioner $8,166 for her services in 1995.
During the years in issue, petitioner maintained her
personal residence in Ponte Vedra Beach, Florida, where she
lived alone. Ponte Vedra Beach is located in the metropolitan
Jacksonville area, about 18 miles from downtown Jacksonville.
During the years in issue, petitioner also rented a 2-
bedroom condominium apartment at Deerwood, a gated, residential
golf course community located in DuVal County (Jacksonville),
about 8 miles from downtown Jacksonville. At various times
during the years in issue, petitioner’s adult daughter, adult
son (a practicing attorney), and elderly mother lived in
petitioner’s condominium at Deerwood.
During the years in issue, petitioner leased an
automobile. Petitioner did not have any other motor vehicle at
her disposal during those years.
Petitioner filed an income tax return, Form 1040, U.S.
Individual Income Tax Return, for 1995. On her return,
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