Michael D. and Christine R. Alexander - Page 13

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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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