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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
Proceedings
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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