James A. and Debra J. Poyda - Page 4




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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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