Raymond O. Wright - Page 9

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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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