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25, 1998. Although PSEG Global’s records reflect payments to
petitioner in 1998 totaling $159,629, PSEG Global issued
petitioner a Form 1099-MISC on which it reported payments to
petitioner totaling $168,598 during that year. Petitioner ceased
working on behalf of PSEG Global in 1999.
During 1998, petitioner maintained at least two bank accounts
in the United States. The first was maintained under the name of
OU at Wells Fargo Bank, and the second was maintained under the
names of petitioner and M. Cristina A Robles at Home Savings of
America. Amounts totaling $269,767 were deposited into the first
account, and $55,389 was deposited into the second account.1
Petitioner filed a Schedule C, Profit or Loss From Business,
with his Federal income tax return for taxable year 1998. This
schedule named petitioner as the proprietor of a business engaged
in “international business consulting”. The schedule listed the
name of the business as “NAFTA”, and it provided an address in
Mexico City. Neither party addressed the use of petitioner’s
corporation’s name on the Schedule C. Based on petitioner’s
testimony and other evidence in the record, we conclude that the
1The total deposit amounts are those reflected in the bank
deposit summaries prepared by respondent. Respondent calculated
the amount of the deposits using the account statements provided
by petitioner. Several of these statements were not available,
leaving gaps of approximately 2 weeks with respect to Wells Fargo
Bank and approximately 6 weeks with respect to Home Savings of
America. Respondent based his determination solely on the time
periods for which bank statements were available.
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