John A. and Margaret R. Gosling - Page 4

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          petitioner spent much time at his home office performing that                
          duty.  Petitioner also spent time preparing for concerts by                  
          studying scores, researching the composer and musical epoch, and             
          evaluating the caliber of individual participating musicians.                
               Petitioner also used his home office to perform duties that             
          related to his position as an organizer for Hilton Head.  In that            
          capacity, he was both a manager as well as an administrator.                 
          Petitioner used his home office to negotiate contracts for future            
          engagements, prepare schedules for upcoming events, reserve                  
          facilities, and obtain licensing rights.  Petitioner also spent a            
          substantial amount of time on the phone coordinating the hiring              
          of musicians and the procurement of instruments.  Further, he                
          used his home office to prepare promotional literature for                   
          upcoming concerts and to write short story books which he                    
          utilized in conjunction with children's concerts.  Also at the               
          home office, petitioner met with new musicians, counseled                    
          performers, and held minor rehearsals.                                       
               Further, an important aspect of petitioner's role as a music            
          director was to act as the impresario, responsible for attracting            
          talented and well known soloists to perform at Hilton Head.                  
          Petitioner used his home office to establish and maintain contact            
          with such performers.  Almost all of petitioner's efforts in this            
          regard were carried out from his home office.                                

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