- 9 - The parties proceeded as though the extent of personal services performed in a trade or business is measured by hours. We do likewise and start with petitioner’s trade or business as an employee of Symantec. According to petitioner, she spent approximately 15 hours per week working for Symantec. She described in general terms how that time was spent, but she provided little in the way of specifics. Although she maintained a written record regarding her activities as an employee of Symantec, the written record was not made available to the Court. Petitioner’s compensation from Symantec, the lack of any written evidence corroborating her testimony on time she claims to have spent performing personal services for Symantec during 2002, the extent of her obligations to her customers as an account manager of Symantec, and the amount of hours she spent working for Symantec in previous years strongly suggest that she spent more than 15 hours per week performing personal services for Symantec during 2002, but the suggestion is no substitute for evidence. As it stands, the only evidence on the point is petitioner’s testimony. Assuming, without finding, that petitioner’s estimate is accurate, we proceed as though petitioner spent 780 hours (15 hours per week x 52 weeks) performing services as an employee of Symantec during the year in issue.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008