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Publishing (NCP), an electronic publishing company dedicated to
acquiring the rights to romance novels delivered over the
Internet.
Regardless of who owned its stock at any given time, CWS
functioned, more or less, in the same way from its inception at
least through the years in issue. Through its employees, which
at all times included petitioner and from time to time other
welders, CWS provided welding services to companies involved in
the construction industry. CWS competed for and was awarded
contracts at times as a result of petitioner’s reputation in the
industry and at other times based upon estimates or bids prepared
by petitioner. CWS’s ability to generate income depended upon
petitioner’s efforts to secure contracts and provide the
necessary welding services in accordance with such contracts.
For the most part, the construction projects involving CWS
and petitioner were located throughout the United States, usually
a substantial distance from where he maintained his residence at
the time. Consequently, petitioner spent a significant portion
of any given year traveling away from home as an employee of CWS.
This was true in 1994, but because he was in the process of
building a personal residence during 1995, petitioner’s travel as
an employee of CWS was greatly reduced that year.
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