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          Emile or Louise rendered any significant advice to Haff in the              
          capacity as an employee (as opposed to a director) that was                 
          necessary or significant enough to distinguish Emile and Louise             
          from petitioner’s other employees.  In fact, the record reveals             
          that Emile and Louise performed during the subject years mainly             
          the type of clerical, nonmanagerial work that could be performed            
          by the staff employees of an office.  The record also reveals               
          that both Emile and Louise devoted significantly less than 100              
          percent of their time to petitioner, given the fact that each of            
          them worked significant hours on the business of the related                
          entities of the Haffner/Fournier family.                                    
               Nor do we believe that petitioner’s business would have                
          suffered had Emile or Louise severed his or her affiliation with            
          the company.  Any void created by the loss of Emile and/or                  
          Louise could have been filled by one or more other employees.               
          Emile’s and Louise’s circumstances in this case are fairly common           
          in the world of closely held business.  Presumably, they were               
          vibrant, energetic, and highly productive individuals in                    
          petitioner’s earlier years, when its business grew and became               
          successful.  In order to manage that growth, however, they                  
          developed an organizational structure that included the next                
          generation of managers and support staff.  Throughout the years,            
          Emile’s and Louise delegated many of their managerial                       
          responsibilities to the new organization so that Emile’s and                
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