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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Last modified: March 27, 2008