Vanessa K. Bernardo - Page 4

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          head of household filing status are encompassed in the findings             
          of fact relating to petitioner’s Schedule C deductions.  Certain            
          facts relating to respondent’s imposition of the section 6662(a)            
          penalty are included in the discussion of that issue.                       
               At the time the petition was filed, petitioner resided in              
          Mechanicsburg, Pennsylvania.                                                
          Petitioner’s Schedule C Activity: Cool G Records                            
               During 1999, petitioner and Melissa were involved in efforts           
          to further Melissa’s career as a composer of songs, a performer             
          (singing her own material) in clubs, a recording artist, and,               
          through Cool G Records, a producer of her own recorded                      
          performances.                                                               
               Melissa was born on December 8, 1979.  Her desire to be a              
          performer manifested itself at an early age.  She took dancing              
          lessons, paid for by petitioner, starting at the age of 8.  As a            
          child, Melissa also learned to play the clarinet and violin, both           
          with petitioner’s financial support.  Melissa persuaded                     
          petitioner to permit her to transfer from her local high school             
          in Orange County, California, to the Los Angeles High School for            
          the Performing Arts, despite the long, daily commute that that              
          would entail.  While still in high school, Melissa briefly                  
          studied music and drama at California State - LA.                           
               Melissa graduated from the Los Angeles High School for the             
          Performing Arts in 1997.  During 1998, she attended the FIT                 






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