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address of Topping White is in West Palm Beach, Florida, which is
also petitioner’s place of residence. Petitioner uses her home
office to handle all financial aspects of her design business.
The assets of petitioner’s activities include horses, a truck, a
trailer, and an automobile. Petitioner uses the truck, trailer,
and automobile for both the equestrian and design activities. In
May of 1999, petitioner hired Deborah Martin (Ms. Martin). Ms.
Martin’s primary responsibilities include general administrative
work, such as preparing invoices, dealing with clients,
collecting money, ordering supplies, scheduling contractors, and
entering information into a computer. Petitioner also relies
upon trainers both to refer clients and improve her performance
as a competitor. Moreover, petitioner works with architects,
electricians, plumbers, furniture manufacturers, and other
experts in their trades in order to run the interior design
aspect of her business. Every one of the trainers that
petitioner has worked with has referred at least one design
client to petitioner. Petitioner also engages C.P.A. Borofsky to
handle her accounting matters.
Petitioner’s business methodology consists of entering in
and attending horse shows, and making contacts with prospective
clients at the shows. Potential clients develop from horse show
contacts, and then petitioner and Ms. Martin meet with the
potential client. Early on in her business, petitioner tried to
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Last modified: November 10, 2007