- 9 - 2001, satisfying section 469(c)(7)(B)(i). We disagree. Although petitioner was contracted to perform–-and was paid for--full-time employment with Casey, she argues that she worked only 8 hours per week. The evidence, however, contradicts petitioners’ claim. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (stating “we are not required to accept the self-serving testimony of petitioner * * * as gospel.”). The job description for petitioner’s position at Casey specifically states that her position at times required workweeks in excess of 40 hours. Her employment contracts were for full- time employment during the relevant time periods. Even Casey’s payroll records indicate that petitioner worked a full-time schedule: 2,080 per year is the equivalent of 40 hours per week. Although it may be possible that she did not work a 40-hour week each week as documented by payroll–-professional salaried employees often are not on a fixed schedule yet something must be entered into the accounting software--it is not reasonable to assume that a nonprofit organization would pay anyone in excess of $55,000 per year plus benefits for working only 8 hours per week.7 The 2,080 hours Casey’s payroll records show far exceed the 774 hour maximum petitioner would have been able to work and still meet the test outlined in section 469(c)(7)(B). 7 That works out to approximately $132 per hour.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007