John E. and Concetta Lozon - Page 4

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          The NOA amendment provided that the AE agreement remained                   
          unchanged, except as modified by the NOA amendment.  The NOA                
          amendment stated that petitioners continued to be full-time                 
          employees of Allstate.                                                      
               The Neighborhood Office Agent Manual (NOA manual) was a                
          written text of rules and procedures provided by Allstate during            
          the 1989, 1990, and 1991 tax years.  The Allstate NOA manual was,           
          in all material respects, similar to the NOA manual described in            
          Butts v. Commissioner, supra.  Allstate gave petitioners a copy             
          of the NOA manual.  The NOA amendment provided that petitioners             
          remained under the supervision of sales management and would                
          attend Allstate training.  Petitioners believed that the NOA                
          manual was basic material on how to run a business, and, since              
          they knew how to run a business, Mr. Lozon discarded it.                    
               Petitioners' relationship with Allstate could be terminated            
          at will by either Allstate or petitioners.                                  
               An Allstate agency manager performed annual business                   
          analysis reviews (reviews) of petitioners.  These reviews rated             
          petitioners' productivity, quality, retention, program support,             
          customer service, administration, and overall role.  These                  
          reviews rated petitioners on whether they exceeded, met, needed             
          improvement, or required immediate improvement in the categories            
          rated by the Allstate agency manager.  The reviews were 5-minute            
          meetings with the Allstate agency manager once a year in which              






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