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dates and amounts of payments and the hours allegedly worked by
the children. See O’Connor v. Commissioner, T.C. Memo. 1986-444.
This arrangement therefore militates against the deductibility of
the payments.
As they did with their son, petitioners recorded their
daughters’ hours and earnings on a list that they kept on the
refrigerator. The list was not made part of the record.
Petitioners did introduce a summary of each daughter’s hours (the
summaries), as well as a week-by-week description of each
daughter’s tasks titled “1998 Timesheet” (the time sheet). The
time sheet includes the following entries for Margot, the oldest
daughter: (1) “Walk dogs, clean yard and haul garbage. 7.5
hours total for the week”; (2) “Walk dogs, bleach dog bowls,
treat dogs for fleas, clip nails, cut grass in beagle yard.
12.75 hours total for the week”; and (3) “Walk dogs, pick up
yard, hose kennels, pick up kennels, clean sliding doors. 5
hours total for the week”. The time sheet includes similar
entries for JCA and JRA.
It is not clear when the summaries and time sheet were
prepared, or whether the information reflected in those documents
is accurate. Furthermore, as with the tasks that Steven
performed, most of the daughters’ tasks are in the nature of
routine family chores, such as cleaning, mowing the yard, and
taking out the garbage. To the extent the daughters performed
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