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Petitioner resided in Charlotte Hall, Maryland, at the time
she filed her petition. Some of the facts have been stipulated
and are so found. For convenience we combine our findings of
fact and conclusions.
Background
Petitioner has worked as a real estate agent licensed by the
State of Maryland since 1980. Petitioner incorporated Sams, Inc.
in the State of Maryland in 1980 in order to limit her personal
liability from lawsuits which she believed to be potentially
substantial. Petitioner refiled the articles of incorporation
for Sams, Inc. in 1995. Petitioner was the president and the
sole shareholder of Sams, Inc., and the only person providing
services purportedly on behalf of Sams, Inc. Sams, Inc. is an S
corporation for Federal income tax purposes.
During 1996, petitioner also worked as a broker-sales
associate and independent contractor with O’Brien Home Sales,
Inc. and O’Brien Realty, Inc. (collectively referred to as
O’Brien), a real estate agency, pursuant to the terms of an
agent-broker agreement dated March 28, 1991. Although the body
of the agreement indicates that petitioner is the sales
associate, the signature line indicates that Sams, Inc. is the
sales associate.
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