Matthew Hudack and Kristen Hudack - Page 6

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          own computer, fax machine, and cellular phone for use in his                
          sales activities, but he paid no rent or other business expenses            
          (e.g., utilities, office supplies and equipment, furniture, and             
          copier) in connection with the Irvine office.  Those expenses               
          were paid by Manulife.  In the Irvine office, Manulife employed             
          two support staff employees to assist petitioner.                           
               Manulife issued Forms W-2, Wage and Tax Statement, to                  
          petitioner reporting wages or other compensation of $496,053 and            
          $436,891 for 1999 and 2000, respectively.  The Forms W-2 also               
          reported that Manulife withheld the applicable payroll taxes.               
          The Forms W-2 further indicated that petitioner participated in             
          Manulife’s health insurance program, pension plan, and deferred             
          compensation plan.  Manulife did not check box 15 for statutory             
          employee.7                                                                  
               Petitioners timely filed a Form 1040, U.S. Individual Income           
          Tax Return, for each of the years in issue.  Petitioners attached           
          to each return, inter alia, a Schedule C, Profit or Loss From               
          Business.  On each Schedule C, petitioner identified his                    
          principal business or profession as life insurance sales and his            
          business address as the Irvine office.  Petitioner reported the             
          following on the Schedules C:                                               





               7  We note that the 2000 Form W-2 box 15 for statutory                 
          employee contained a handwritten “X”.                                       




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