Anthony S. D'Acquisto - Page 2




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          deductions for the taxable year 1994.  We find that petitioner is           
          an employee and not an independent contractor and therefore                 
          cannot deduct his business expenses on Schedule C.                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner resided in Chicago, Illinois.                         
               In 1994, petitioner, under the stage name Tony Russell,                
          worked as a voice actor providing voice announcements and/or                
          narration for commercials, corporate videos, radio and television           
          promotionals, video games, talking toys, and television shows.              
          Although petitioner provided services for television, cable, and            
          video, petitioner did not appear on screen.  Petitioner began his           
          career as a voice actor by studying communications at the                   
          University of Wisconsin.  Between the years 1977 and 1983,                  
          petitioner worked with NBC as both booth announcer on television            
          and a “swing personality” on radio stations.  After working with            
          NBC, petitioner began providing services to various parties on a            
          contractual basis.                                                          
               During the year in issue, petitioner was a member of both              
          the Screen Actors Guild and the American Federation of Television           
          and Radio Artists (unions).  The unions set minimum standards for           
          performer fees based on a collective bargaining agreement and               






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