Carolyn Lamb - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax in the amount of $11,834 for the taxable year 2000.              
               This is a substantiation case.  After a concession by                  
          respondent, the issue for decision is whether petitioner is                 
          entitled to various Schedule C deductions in amounts greater than           
          those allowed and conceded by respondent.  We hold that                     
          petitioner is entitled to the deductions to the limited extent              
          provided herein.                                                            
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  At the time that the petition was filed, petitioner                 
          resided in Houston, Texas.                                                  
               During 2000, the taxable year in issue, petitioner was self-           
          employed.  She owned and operated two businesses:  a child care             
          business and a property maintenance and cleanup business.                   
          Child Care Business                                                         
               Petitioner operated the child care business out of her                 
          residence.  She generally had 8 to 12 children in her care during           
          the day throughout the workweek.  The children included infants,            
          preschoolers, elementary school students, and a 13-year-old.                
               The children would be dropped off at petitioner’s home by              
          their parents on their way to work, and would be picked up by               
          their parents on their way home.  After dropoff by the parents in           
          the morning, petitioner would drive the older children to school;           






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