Irwin and Jeannine Radnitz - Page 6




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          received wage income of $800 in 1997 and $3 in 1998.  The                   
          relationship of Mr. Radnitz with the film and television industry           
          for whom his writings were created and sold was that of an                  
          employee and was not an independent contractor relationship.                
          Respondent does not challenge that characterization.                        
          Accordingly, the moneys Mr. Radnitz received for his work                   
          products were reflected on Forms W-2, Wage and Tax Statement.               
               Screenwriters are generally not provided office space in               
          which to do their writing.  They are expected to provide their              
          own offices.  As a result, during the years at issue, Mr. Radnitz           
          provided himself with office space for his compositions.  The               
          type and location of the spaces depended on various factors,                
          including cost, convenience, the length of the writing project,             
          and the need for privacy and quiet.  For the majority of the                
          time, Mr. Radnitz used his residence as an office.  However, for            
          two 3-month periods during 1998, he used rented spaces that were            
          outside of his main residence.                                              
               During 1997, Mr. Radnitz spent most of his time writing a              
          screenplay entitled "Home Again".  His office was exclusively at            
          his residence at the Vista Loma address for the first part of the           
          year and at the Deepak address in the latter part.  In 1998, Mr.            
          Radnitz used the office at the Deepak residence in January and              
          February, again from June through August, and in December.  From            
          March through May 1998, he used a rented apartment on North                 





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