- 5 - 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 asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011