Erin Mullin - Page 3




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          on a Schedule A, Itemized Deductions, included with that return.            
               In addition to her employment with the clinic, during 1996             
          petitioner also offered services as a clinical psychologist                 
          through her private practice.  She met with her private-practice            
          patients two afternoons per week at an office that she rented for           
          that purpose in a commercial/medical building.  The income and              
          expenses (including the office rental expense) attributable to              
          her private practice are reported on a Schedule C, Profit or Loss           
          from Business, included with her 1996 return.                               
               During 1996, petitioner lived in a small (approximately 400            
          square feet) rented apartment in San Francisco (the apartment).             
          The only entry to the apartment is through a door that leads to a           
          short entryway.  There is a closet on the left of the entryway              
          and a bathroom on the right of the entryway.  The entryway opens            
          into an open area (approximately 13 feet by 15 feet) that is                
          furnished with at least a desk and a couch.  To the right of this           
          open area is a dining area and a kitchen (each approximately 7              
          feet by 8 feet).  Getting to the kitchen from the bathroom, and             
          vice versa, requires going through the dining area, the open area           
          adjacent to the entryway, and the entryway.                                 
               Petitioner used the telephone in her apartment to schedule             
          appointments with, or otherwise speak to her private-practice               
          patients and professional colleagues.  She also maintained and              








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