Sarah A. Bland-Barclay and Francis Barclay - Page 4




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          Employer                      Employee            Amount                    
          GM North American Operations  Francis Barclay     $80,595.65                
          Truck & Bus Group                                                           
          VTR Services, Inc.                                                          
          T/A Jackson Hewitt Tax Serv.  Sarah A. Bland Barclay   3,639.46             
          Defense Finance and AccountingSarah A. Bland Barclay     432.48             
          Service                                                                     
          Manpower International, Inc.  Sarah A. Bland Barclay   1,615.00             
          Total                                             $86,282.59                
               Attached to their 1996 income tax return were three Schedule           
          C forms for three businesses petitioner engaged in, in addition             
          to her part-time employment.  These businesses were Barclay’s               
          Consulting Services, Barclay’s Notary Services, and Barclay’s Tax           
          Services.  All of these businesses were carried on by petitioner            
          from her residence.  Petitioner reported gross receipts from                
          Barclay’s Consulting Services of $828 and business expenses of              
          $8,164, resulting in a net loss of $7,336.  Petitioner reported             
          $0 gross receipts from Barclay’s Notary Service and business                
          expenses of $2,721, resulting in a net loss of $2,721.  For                 
          Barclay’s Tax Services, petitioners reported gross receipts of              
          $7,635 and expenses of $24,568, resulting in a net loss of                  
          $16,933.                                                                    
               In a notice of deficiency, respondent determined that                  
          petitioner received additional wages of $1,267, which she and Mr.           
          Barclay failed to report on their return.  Respondent further               
          determined that they were not entitled to Schedule A itemized               






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