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Petitioner was engaged as an independent contractor in two
trade or business activities during the years at issue: a
ministerial activity and an insurance sales activity.
The insurance activity consisted of the sales of various
types of insurance to senior citizens. The various categories of
insurance petitioner offered included insurance for long-term
care, supplementary Medicare benefits, home health care,
annuities, and life insurance. Petitioner was affiliated with an
insurance brokerage firm from which petitioner was provided a
customer list of insured persons. From this list, petitioner
serviced policy holders having problems or questions regarding
their coverage, and he endeavored to sell them other coverage
they did not have. Any applications for such insurance were
taken by petitioner, who then forwarded the applications to the
insurance brokerage firm for processing and the ultimate issuance
of insurance by an insurance provider. The insurance brokerage
firm was located approximately 50 miles from petitioner's
residence. Petitioner was not provided an office by the
brokerage firm, nor was he required to report or visit the office
of the brokerage firm. None of petitioner's work was conducted
at the brokerage firm's office. Petitioner worked out of his
home, which was an apartment he rented at Lake Wales, Florida.
He worked at hours of his choice. Petitioner's means of getting
business was contacting individuals listed on the customer list
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