Michael D. and Christine R. Alexander - Page 17

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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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