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to Steven were intended as and constituted payments for bona fide
business employment. See Furmanski v. Commissioner, supra.
Mrs. Alexander testified that she calculated she could pay
Steven approximately $4,000 for the summer. Steven therefore was
paid a flat amount determined at the beginning of the year rather
than an amount based on the services he actually performed. This
fact militates against the deductibility of the payments. See
Furmanski v. Commissioner, supra.
Petitioners paid Steven the majority of the $4,000 either
before he started working in the summer or well after the summer
had ended. Thus, there was a lack of correlation between the
dates of the payments and the hours Steven worked. This fact
also weighs against the deductibility of the payments. See
O’Connor v. Commissioner, supra.
Petitioners recorded Steven’s hours and wages on a list they
kept on their refrigerator. Although the list was not introduced
into evidence, the information contained thereon appears to be
summarized in the document titled “Steven’s Hours”. See supra
note 3. Petitioners also introduced a document titled “Steve’s
Summer Work Schedule” (the schedule). The schedule lists a
number of tasks and hours worked, such as: (1) “Go get thread
and machine needles at fabric store. Pick up bags for vacuum
cleaner. Learn how to draw up pattern from measurements. 7
hours”; (2) “Clean sewing room, box up materials and move
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