S.W. DePasture - Page 5





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          Publishing (NCP), an electronic publishing company dedicated to             
          acquiring the rights to romance novels delivered over the                   
          Internet.                                                                   
               Regardless of who owned its stock at any given time, CWS               
          functioned, more or less, in the same way from its inception at             
          least through the years in issue.  Through its employees, which             
          at all times included petitioner and from time to time other                
          welders, CWS provided welding services to companies involved in             
          the construction industry.  CWS competed for and was awarded                
          contracts at times as a result of petitioner’s reputation in the            
          industry and at other times based upon estimates or bids prepared           
          by petitioner.  CWS’s ability to generate income depended upon              
          petitioner’s efforts to secure contracts and provide the                    
          necessary welding services in accordance with such contracts.               
               For the most part, the construction projects involving CWS             
          and petitioner were located throughout the United States, usually           
          a substantial distance from where he maintained his residence at            
          the time.  Consequently, petitioner spent a significant portion             
          of any given year traveling away from home as an employee of CWS.           
          This was true in 1994, but because he was in the process of                 
          building a personal residence during 1995, petitioner’s travel as           
          an employee of CWS was greatly reduced that year.                           









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