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petitioner’s nephew helps her maintain the building and its
grounds.
The building has nine offices, a waiting room, and a
bathroom. Petitioner’s two brothers play videogames and use
their computers in one of the building’s offices. Another office
is used as a prayer room by a volunteer missionary who provides
free counseling services. Still another office houses a reading
room with books on religion and a computer on which visitors can
access and view six different versions of the Bible. Petitioner
provides reflexology and mortgage broker services in other rooms
of the building; according to her testimony, she provides these
services to maintain income for the memorial. Petitioner also
thought these activities would be good ways to provide for her
retirement.
From 2000 through late 2002, petitioner’s activities
reported on Schedule C, Profit or Loss from Business, were
operated under the trade name of Lila Osborne Memorial
(Memorial). The Schedules C for the Memorial, however, reflect
only a single activity, reflexology services. Petitioner
testified that it was her intent that the Memorial be an umbrella
organization for all of her various activities.3
3 Although petitioner created Benson Exposition, Inc., an S
corporation, in late 2002 to be the umbrella organization for the
memorial and her various activities, she continued to report
income and expenses on Schedules C listing Lila Osborne Memorial.
(continued...)
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