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to deal with insurance companies. The ethnic makeup of
petitioner's clientele had changed to the point that
approximately 80 to 90 percent of petitioner's clients were
Koreans, most of whom did not speak English. Since petitioner
did not speak Korean, he was forced to rely on Mr. Yoon and
employees in the office to communicate with clients. The
reported gross receipts on petitioner's Schedule C grew as
follows during the years in issue:
Year Schedule C Gross Receipts
1988 $73,741
1989 228,091
1990 445,551
1991 (amended) 708,075
Mr. Yoon departed the firm in 1993.
Mr. Yoon's Role in the Office
It was at Mr. Yoon's suggestion and coaxing that petitioner
decided to open an office in Koreatown and to develop a client
base in the Korean community. From the outset, Mr. Yoon assumed
a major role in the office. Mr. Yoon would make initial contacts
with clients, obtain information, act as translator, and prepare
much of the paperwork relating to the client's matter. Mr.
Yoon's compensation in the initial stages of his arrangement with
petitioner was sporadic and based on the availability of funds in
the office.
Mr. Yoon was active in securing clients for the firm. Mr.
Yoon would locate the client, secure the client's signature on
the retainer agreement, initiate contact with the insurance
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