- 3 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008