Leslie A. and Betsy M. Roy - Page 3

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          in economics.  For the taxable years at issue, petitioner worked            
          as one of several farm managers.                                            
               In his capacity as manager, petitioner is required to live             
          on or in close proximity to the farm.  He has personnel to manage           
          on a daily basis.  Each morning, petitioner awakens to laborers             
          waiting outside his house in hopes of getting work for the day.             
          Petitioner is responsible for hiring and firing these laborers,             
          as needed, on the land he oversees.                                         
               Petitioner also must be available at various times of the              
          day and night as part of his management of the land.  The hops              
          season runs for 11 months out of the year, with a 6-month cycle             
          of around the clock irrigation.  The laborers work 24 hours a day           
          in August to harvest the 1,300-acre crop.  The apple orchard                
          requires 24-hour attention from April through October, and the              
          cattle require 24-hour attention during calving season.  During             
          irrigation season, the managers must watch for broken pipes, and            
          during frost season, managers are on call for frost alarms which            
          require immediate response.  Farming equipment must be closely              
          monitored to avoid vandalism and to ensure the security of the              
          machinery.  For this reason, petitioner sometimes stores farming            
          vehicles and other equipment on his property.                               
               In addition to tractors and trucks, petitioner also provides           
          storage space for ladders and packing boxes that are used                   
          throughout the season.  On the 5-acre parcel of land surrounding            





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