Melinda D. Rivera - Page 3

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               Respondent determined a deficiency in petitioner's Federal             
          income tax of $4,122 for 2000.  After concessions,1 the issues              
          remaining for decision are:  (1) Whether petitioner, during the             
          year at issue, was a statutory employee under section                       
          3121(d)(3)(D); (2) whether petitioner is liable for self-                   
          employment tax; and (3) whether petitioner is entitled to                   
          deductions for either employee business expenses on Schedule A,             
          Itemized Deductions, or trade or business expenses on Schedule C,           
          Profit or Loss From Business, under section 162(a).                         
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioner                  
          resided in Oakland, California, at the time the petition was                
               Petitioner timely filed her Form 1040, U.S. Individual                 
          Income Tax Return, for 2000.  Attached to the return were three             
          Forms W-2, Wage and Tax Statement, in petitioner's name reporting           
          wages as follows:                                                           
                    Big Train, Inc.               $35,142.29                          
                    Peerless Coffee Co., Inc.     9,373.48                            
                    George W. Riley Professional                                      
                    Beauty Center                 757.87                              

               1Petitioner conceded at trial that she was not a statutory             
          employee of her employers George Riley and Victoria's Secret.               
          Petitioner only worked for Victoria's Secret for only 1 day.                

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