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During the years in question, petitioner was employed full
time as an administrative assistant by Columbia University, from
which she reported wage income of $40,329 for 1999 and $39,824
for 2000.
In addition to her position as an administrative assistant,
petitioner was working as a “field trainer” for American
Communications Network (American), a telecommunications company
that provides, inter alia, long-distance, Internet, and paging
services. Petitioner commenced working for American in 1996 and
was primarily involved in the solicitation of customers for the
company. Petitioner sought to attract customers by holding
receptions at her home every weekend and occasionally on
weekdays. She also attended individual meetings with customers
to discuss the business. Petitioner’s compensation for her work
for American consisted of a percentage of her customers’ phone
bills.
Petitioner filed her Federal income tax returns for 1999 and
2000 as a head of household and claimed, for each year, a
dependency exemption deduction for her brother. With respect to
her work for American, on Schedule C petitioner reported gross
income of $657 for 1999 and $327 for 2000 and claimed numerous
deductions resulting in net losses from the activity for those
years of $26,715 and $25,902, respectively. In addition to the
Schedule C deductions, petitioner filed a Schedule A, Itemized
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