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Daryl Kell is a highly regarded and eminently qualified
music editor. Petitioner, through Daryl Kell, rendered music
editing services for productions of feature films, television
movies, and programs. The music editing service that petitioner
provides involves the rental and use of petitioner’s computer
equipment. Music editing is an artistic and technical
undertaking requiring judgment, artistic ability, and discretion.
Daryl Kell's work as a music editor for petitioner’s clients
requires creative decision making. Music editing is a
collaborative effort by all involved in a given production and
involves forming very close relationships between music editors
and those with whom they work.
Petitioner had taxable years ending on January 31 for each
year in issue. At all times during the taxable years in issue,
Daryl Kell owned 100 percent of petitioner’s stock, and he was
petitioner’s sole officer and director. Other than officer’s
compensation paid to Daryl Kell, petitioner paid no salary or
compensation to employees.
The International Alliance of Theatrical and Stage Employees
(IATSE) is a union. In the productions in which petitioner was
involved music editors were required to be members of IATSE.
Daryl Kell was a member of IATSE. In order to employ a music
editor who was a member of IATSE the employer was required to be
a signatory to the IATSE agreement. Petitioner was not a
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