Walter R. Strohmaier - Page 5




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          provided by the brokerage firm or responding to individuals who             
          had service requests on their existing coverage.  Petitioner did            
          not receive or interview clients at his apartment.  Instead,                
          petitioner went out and met with potential clients.  Petitioner             
          did not employ anyone to assist him in his activity.  As                    
          petitioner explained at trial:                                              

               The agency [the brokerage firm] had sufficient business                
               on the books that I could cultivate business from my                   
               home by simply looking at the records * * *.  I would                  
               make a phone call or I would show up at the person's                   
               house.  But when I went to that individual's house, I                  
               already knew what he had.  And I had a proposal in my                  
               attache case saying, this is what I'm going to sell                    
               that individual, which was homework done at my home                    
               office.                                                                
               *     *     *     *     *     *     *                                  
               my position * * * is that the business is a home-based                 
               business, in that the majority of the paperwork, the                   
               grunt work, is done prior to going out to a client's                   
               home.  And, because there is no structured territory or                
               structured requirements, since I am totally                            
               independent, my understanding of the Internal Revenue                  
               Code is that this qualifies as a home business.                        

               Petitioner performed services as a minister for                        
          approximately 6 months each year, essentially during the winter             
          and spring.  Petitioner was not affiliated with a particular                
          church.  His ministerial activity consisted of serving as a                 
          chaplain to a mobile home community located approximately 35                
          miles from Lake Wales, Florida.  That community consisted of                
          people petitioner referred to as "snowbirds", which he defined as           





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