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Mrs. Lozon (sometimes referred to as petitioner) has been
associated with Allstate since October 14, 1985, and Mr. Lozon
has been associated with Allstate since July 14, 1989, the
respective dates that they entered into Agent Employment
Agreements (AE agreements) with Allstate. Petitioners' AE
agreements were, in all material respects, similar to the
agreement1 described in Butts v. Commissioner, T.C. Memo. 1993-
478, affd. per curiam 49 F.3d 713 (11th Cir. 1995).
Petitioners were Neighborhood Office Agents (NOA's) during
the years in issue.2 The NOA concept was promoted by Allstate as
a means of becoming an entrepreneur, having one's own office, and
being one's own boss. Petitioners' relationship with Allstate
was governed by the AE agreement and the Neighborhood Office
Agent Amendment to the Allstate Agent Compensation Agreement (NOA
amendment). Such amendment was in all material respects similar
to the NOA amendment described in Butts v. Commissioner, supra.
1 The parties stipulated that "petitioner's Allstate Agent
Employment Agreement was in all material respects similar to Dan
Butts' Allstate Employment Agreement, as described in [Butts]."
In Butts v. Commissioner, T.C. Memo. 1993-478, affd. per curiam
49 F.3d 713 (11th Cir. 1995), the taxpayer entered into an
"Allstate Agent Compensation Agreement"; the opinion makes no
reference to an "Allstate Agent Employment Agreement". Although
petitioners later entered into an "NOA amendment to Allstate
Compensation Agreement", there is no reference in the record to
petitioners having entered into an "Allstate Compensation
Agreement". See infra. We interpret the parties' stipulation to
mean that petitioners' written agreements with Allstate were in
all material respects similar to the taxpayer's in Butts.
2 Unless otherwise indicated, descriptions of petitioners'
business pertain to the years in issue.
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