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degree in business and finance from the University of San
Francisco. Petitioner held a number of jobs before 1998, the
year she began working for Bank of America in the fields of
finance and securities investment. She worked for Bank of
America until she was released sometime in 2001.
In connection with her release, petitioner received
“settlement fees” of $400,000 from Bank of America during 2002.4
In addition, petitioner received unemployment compensation of
$13,840 that year. With the money received from these sources,
petitioner began an activity as a real estate finder and
consultant, an activity that allowed her to attend to her two
minor children.5 Petitioner testified that she traveled to
Hawaii, Korea, China, and Las Vegas during 2002 on behalf of her
clients to search for prospective real estate investment
opportunities. However, petitioner’s lack of a salesperson’s
4The nature and terms of these fees were not made part of
the record; however, petitioners included the $400,000 as income
on their income tax return for 2002.
5Petitioner decided to begin an activity as a real estate
finder and consultant sometime in September 2001. Petitioner
claimed that as a real estate finder she searched for real estate
investments on behalf of clients interested in purchasing
property. She would, assuming that properties she recommended
were purchased, receive a fee for her services. At trial,
petitioner conceded that she did not enter into any written
agreements in 2002 with her clients. Although she testified that
she had numerous e-mail exchanges with clients during the year at
issue, she did not offer into evidence any of these e-mail
communications. Petitioner claimed she had oral agreements
regarding fee arrangements with her clients.
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