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stated:
These expenses [$6,918] are correctly reported on Sch.
C because of my statutory employee status. I travel as
an outside sales person and my car expenses are shown
as other income on the Sch. C. I have requested a
confirmation of my duties with my employer and should
be receiving it shortly! Please hold this file until I
can get this confirmation. I now feel that my income
should not be on line 7!
Respondent received the second letter on December 13, 2000.
As suggested in her second letter, petitioner obtained
another letter, dated January 11, 2001, and written by Chris
Bastin, District Manager of the Tennessee Region for Arch
Wireless (third letter). The third letter purported to confirm
petitioner’s employment and stated, in part:
The purpose of this letter is to verify that Jennifer
Rusley worked for Arch Wireless as an Outside Account
Executive from 7/15/97 to 10/9/98. During this time
Jennifer’s responsibilities included outside business
to business sales and service for new and existing
customers.
Respondent received the third letter, but the record does not
establish how or when petitioner transmitted the letter or the
date of receipt by respondent.
On February 20, 2001, respondent issued a statutory notice
of deficiency disallowing petitioner’s Schedule C expense
deductions. On May 16, 2001, petitioner’s representative,
William De Montbreun, a certified public accountant, mailed a
petition to this Court by certified mail. Both petitioner and
Mr. De Montbreun signed the petition, and it was filed on May 21,
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