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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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