Carolyn D. Fenderson - Page 4

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          customers in Cleveland and Pittsburgh.  She spent at least 50               
          hours a week doing so.                                                      
               Petitioner’s compensation from Symantec was composed of a              
          base salary, stock options, and sales commissions based on sales            
          of software licenses.  Depending on the size and nature of the              
          sale transaction, a series of licenses involved in a single sale            
          might be “rolled out” over a period of years following the year             
          of the sale.  Her commissions were paid when the “roll out”                 
          occurred.  As a result, petitioner received commissions in one              
          year that related to sales made during a previous year or years.            
               In 2002 petitioner’s compensation from Symantec totaled                
          $186,487.  Some of the commissions included in that amount relate           
          to sales of software licenses made in years prior to 2002.                  
          According to petitioner, she spent about 15 hours a week working            
          for Symantec during 2002.  She maintained a calendar that tracked           
          her activities and appointments in connection with her employment           
          at Symantec, which ended during 2003.                                       
               As of the close of 2002 petitioner owned several parcels of            
          residential real estate that she held for rent, or rented during            
          that year (collectively, the rental units).  Some of the rental             
          units were leased in accordance with Federal or State programs              
          that provided rent subsidies to the tenant(s)/lessee(s) (the rent           
          subsidy programs).  On her timely filed 2002 Federal income tax             

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