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Aerospace paid petitioner by means of checks at 2-week intervals
in the amount of $2,000,5 which carried the notation "consulting
fees".
The $12,150 in self-employment income determined by
respondent for 1989 consists of $6,150 in remuneration for
petitioner's services paid by Charles River Computers (Charles
River) and $6,000 from Solutions Plus, Inc.6 A Confidentiality
Agreement entered into by petitioner and Charles River provided
that petitioner would receive $750 per week for "� time" and
makes reference to petitioner's performance of "consulting and
other services". A provision in the agreement prohibiting
petitioner from engaging in any other business during the term of
the agreement was lined through. Petitioner did not provide
specific descriptions of his work in 1989 except to claim that,
as in 1987, such work was always performed on the purported
employer's premises, was subject to established working hours,
and was nondelegable.
5 One such check was for $1,900 instead of $2,000, which
petitioner testified was due to the fact that he was "docked"
one-half day's pay ($100) when he was absent from work one
morning.
6 The only identification of the source of the 1989 amounts
determined to be self-employment income was in petitioner's trial
memorandum, where he appears to acknowledge that $6,150 of such
amounts was from "Charles River Computers" and $6,000 was from
"Solutions Plus". Petitioner does not, in any event, dispute
that taxable income in these amounts was received.
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