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choirs, conducted rehearsals, selected music, and located
instruments for musical performances for PH. In addition,
petitioner assisted with the cleaning, painting, and plumbing for
PH. Petitioner did not receive a salary or other compensation
from PH.
In 1989, petitioner formed a joint venture with Art Glass,
who was also the chairman of PH, to develop software and a
computer system for churches. In theory, this computer system
would allow the pastor to select and play music at the touch of a
button from the pulpit. In addition, they intended to develop
financial and record-keeping software for churches. Petitioner
and Mr. Glass planned to sell the software, music, and computer
to interested churches.
Mr. Glass offered testimony about various activities of the
joint venture, but was uncertain as to whether they occurred in
1989 or 1990. According to his testimony, he and petitioner made
several trips to a recording studio in Ontario, California, to
record various instruments such as the piano, organ, and drum to
use in developing the computer software. Mr. Glass also testified
that he and petitioner attended a music conference in
Philadelphia, Pennsylvania, to observe trends and changes in
black church music. In addition, Mr. Glass testified that he and
petitioner attended several computer shows to see the latest
computer technology and to locate a specific organ sound for
their computer system.
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