Lisa Beth Levine - Page 12

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          recommendations.  Mr. Urman noted that petitioner had adapted to            
          her responsibilities without having the advantage of a mentor or            
          Mr. Urman’s close supervision.  He rated petitioner’s performance           
          outstanding and recommended her for future contracts.                       
          B.   Petitioner Released From Second Personal Service Contract              
               and Appointed Federal Employee                                         
               On November 19, 1999, the State Department released                    
          petitioner from the second personal service contract and hired              
          her as a full-time, permanent, appointed, Federal employee as an            
          industrial hygienist.  Pursuant to the personal service                     
          contracts, petitioner’s service under the contracts did not apply           
          toward her annual leave accrual rate or retirement credit for               
          direct hire service.  Petitioner was not paid for any unused                
          accrued sick leave, and the leave was not carried over as a                 
          credit under her direct hire service.                                       
               Her appointment was subject to completion of a 1-year                  
          probationary period beginning November 11, 1999.  Her service for           
          purposes of career tenure and FERS/FSPS began November 11, 1999.            
          C.   Contribution to Simplified Employee Pension, Deduction on              
               the 1999 Return, Notice of Deficiency, and Tax Court                   
               On March 10, 2000, petitioner made an $8,638 contribution to           
          her simplified employee pension for 1999.  Petitioner calculated            
          the contribution on the basis of the income she earned under the            
          personal service contracts.                                                 

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