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dedicated significant time to running the company; and (4) they
reported only small amounts of income from other sources. On
these bases, respondent asserts that the Robinsons were carrying
on a trade or business.
The fact that an individual did not receive remuneration in
the form of wages or that the individual reported self-employment
income (or other remuneration besides wages) on a Schedule C does
not prevent the individual from being classified as an employee.
Pariani v. Commissioner, T.C. Memo. 1997-427; Jacobs v.
Commissioner, T.C. Memo. 1993-570. In addition, many of the
facts upon which respondent relies in this case for the
determination that Mr. and/or Mrs. Robinson were engaged in an
independent trade or business also support the Robinsons’
argument that each of them, as an officer or common law employee,
provided significant services that were integral to the operation
of the company.
Mr. Robinson was an officer of the corporation and its sole
shareholder in 1992 and 1993. He provided substantial services
to the corporation in his capacity as an officer. Because of his
expertise as a certified aircraft mechanic and pilot, he was
involved in overseeing the day-to-day operation of the aircraft
brokerage segment of Career’s business. He was personally
involved in the inspection, negotiation, and purchase of used
aircraft and parts. He traveled extensively for this part of the
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