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During the years in issue, petitioner husband (petitioner)
was primarily employed as the music director of the Hilton Head
Orchestra, a community orchestra, and the Hilton Head Choral
Society (collectively, Hilton Head). As a music director,
petitioner rendered services in a number of capacities: as a
conductor, as an organizer or producer, and as an impresario.
During that same year, petitioner was also employed as the choir
conductor for the First Presbyterian Church, and as an adjunct
professor of music at the University of South Carolina, Hilton
Head branch. For a brief period during 1993, petitioner was
employed as the principal guest conductor of the Savannah
Orchestra. None of the various entities that employed petitioner
provided him with an office.
Petitioners reside in a four bedroom single-family home.
Throughout the years in issue, the fourth bedroom of petitioners'
house was used exclusively by petitioner as a home office. The
room was set up as a typical office, containing a desk, shelving,
a computer, filing cabinets, and other office equipment used by
petitioner to perform business-related duties.
Petitioner spent the majority of his working hours at his
home office. Part of that time he performed duties related to
his position as a conductor. An important aspect of petitioner's
job as a conductor was to select the repertoire for each concert.
Selecting the repertoire was a time consuming process, and
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