Calypso Music Incorporated - Page 3




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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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Last modified: May 25, 2011