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No one from Techmatics or its successor, Anteon Corp.,
testified at trial. However, the personnel file of petitioner
was obtained from Anteon through a subpoena duces tecum and
jointly submitted into evidence. In addition to the employment
agreement and various correspondence, the records included Salary
Review Worksheets periodically prepared by Techmatics personnel
regarding petitioner. These reviews reflected ratings in which
petitioner met or exceeded expectations. The 1998 review
increased petitioner’s compensation from $50 to $52 per hour.
The records support petitioner’s assertion that he worked at home
but do not show whether Techmatics would have provided petitioner
with office space had he requested it.
The compensation petitioner received from Techmatics during
1998 totaled $26,516, which was reflected on Form W-2. That
income was reported by petitioner on his 1998 Federal income tax
return as wage and salary income. However, petitioner also
included with his 1998 return a Schedule C in which he claimed as
deductions the expenses incurred in connection with his activity
with Techmatics. The expenses totaled $13,480. No gross
receipts were reported on Schedule C; however, a notation on the
income portion of Schedule C included the statement “See attached
–- W-2 -– Techmatics.” Thus, the Schedule C reported a net loss
of $13,480; consequently, there was no computation of self-
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