David M. and Audrey J. Fugitt - Page 4

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          Liquidators (Southeast).  Southeast is a recreational vehicle               
          broker owned by Roger Ruess (Mr. Ruess).  Petitioner worked for             
          Southeast throughout Florida for 106 days during 1999.                      
               For a portion of 1999, Southeast conducted temporary offsite           
          recreational vehicle sales shows (RV shows) on behalf of Revels             
          Nationwide RV (Revels).3  Southeast would set up the RV shows and           
          sell recreational vehicles on behalf of Revels.  The RV shows               
          typically lasted between 3 to 5 days.  Revels did not participate           
          in the sales at the RV shows.4  At the end of each RV show, Mr.             
          Ruess delivered all sales contracts to Revels.                              
               Southeast’s salesmen sold recreational vehicles to customers           
          at the RV shows.  At the time of each sale, the salesman prepared           
          a worksheet.  James Osburn (Mr. Osburn), a subcontractor who                
          worked for Mr. Ruess, generally prepared the sales contract from            
          the salesman’s worksheet.  Either Mr. Ruess or Mr. Osburn                   
          approved each sale negotiated by a salesman.                                
               Mr. Osburn maintained a computer database of the sales made            
          by each salesman.  The information from each sales contract was             
          contemporaneously recorded in the computer database for the                 
          appropriate salesman at the time of each sale.                              


               3  In 1999, Revels sold recreational vehicles at its sales             
          lot located in Jacksonville, Florida, and at RV shows held                  
          throughout Florida by Southeast.                                            
               4  In situations where customers offered less than the cost            
          of the recreational vehicle, Revels was contacted to approve the            
          sale.                                                                       





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