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time, work on the farm directly involving the trees--such as
mowing, fertilizing, pruning, and shearing--occurred in the
months of May through September. Other business activity
continued through winter months, but these months were not as
busy as summer.
During 1995 and 1996, Ms. Poyda worked 2 days a week at the
Medford Area Chamber of Commerce. In addition, she worked an
undetermined amount of time with the Christmas tree farm and also
helped in keeping the books and records for petitioners’ other
endeavors in logging and the growing of ginseng. All of
petitioners’ activities were conducted out of a home office. No
records were maintained by petitioners documenting the amount of
time Ms. Poyda spent on farm activities.
According to the Forms W-2 issued by Mr. Poyda to Ms. Poyda
in 1995 and 1996, she respectively earned $5,200 and $5,400, or
an average monthly salary of approximately $433 and $450. Ms.
Poyda earned $6,857 in 1995 and $6,525 in 1996 from her 2-day-
per-week job at the Medford Area Chamber of Commerce. She
received no compensation for work done in connection with
petitioners’ logging and ginseng activities.
Mr. and Ms. Poyda and their four children received benefits
in the form of health insurance coverage and medical expense
reimbursement from a plan provided to Ms. Poyda, purportedly in
connection with her status as an employee of the farm. This
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