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Unless otherwise indicated all section references are to the
Internal Revenue Code in effect for the year at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, accompanying exhibits, and stipulation
of settled issues are incorporated by this reference.
Petitioners resided in Houston, Texas, at the time they filed the
petition.
Petitioner was employed by Armko Industries, Inc. (Armko), a
roof system consulting firm, as a sales representative during
2000. Petitioner was responsible for consulting with clients,
predominantly school districts, regarding their roofing needs and
assisting them in overseeing the planning and implementation of
roofing projects. This included identifying the condition of the
current roof, developing specifications for the project, meeting
with local construction contractors who bid on the project, and
attending preconstruction meetings with the school district and
the contractors. Once construction began, petitioner documented
the progress and authorized payments to the contractors. When
the project was completed, petitioner prepared a list of items
that had to be remedied before the contractor would be paid and a
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