Teddy R. and Cheryl D. McGinty, Jr. - Page 3

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               Respondent determined a deficiency of $1,100 in petitioners’           
          Federal income tax for the taxable year 1999.  The issues for               
          decision are:  (1) Whether petitioners failed to report $3,914.15           
          of income; and (2) whether petitioners are liable for self-                 
          employment tax on the $3,914.15.                                            
               Some of the facts in this case have been stipulated and are            
          so found.  The stipulation of facts and the attached exhibits are           
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioners lived in Long Beach, California.                     
          References to petitioner in the singular are to Cheryl D.                   
          McGinty.                                                                    
               Petitioners were married in April 1998.  From August 1996              
          through May 2000, petitioner attended the University of                     
          California at Berkeley (university).  Petitioner used her maiden            
          name, Cheryl Gomez, while in college.  During most of                       
          petitioner’s college years, her husband was in the United States            
          Marine Corps stationed at Camp Pendleton in Southern California.            
               During the summer of 1999, petitioner lived with her husband           
          in Southern California.  Upon returning to the university for the           
          1999 fall semester, petitioner sought housing.  On a housing list           
          provided by the university, petitioner found a listing placed by            
          Harry S. Dixon.  The listing provided for room and board for a              
          student in exchange for services provided at Mr. Dixon’s home.              
          Petitioner interviewed with Mr. Dixon and was told that her                 





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