James E. Anderson and Cheryl J. Latos - Page 23

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               a.  General Meaning of the Terms in Section 3121(b)(20) and            
               Section 31.3121(b)(20)-1(a), Employment Tax Regs.                      
               The general dictionary definition of “depend” encompasses:             
               1: to be contingent: a: to require something as a necessary            
               condition--used with on or upon (we depend on food to keep             
               us alive) (his life depends on his undergoing an operation)            
               (the merit of his piece depended on the brilliant things               
               which arose under his pen as he went along--Matthew Arnold)            
               b: to become conditioned or based (as by subjection or                 
               relatedness--used with on or upon) (sciences depend on one             
               another) (prices depend upon supply and demand) * * *.                 
               [Webster’s Third New International Dictionary 604 (1974).]             
               The general dictionary definition of “solely” encompasses:             
          “1:  without an associate (as a companion or assistant): singly,            
          alone * * *; 2: to the exclusion of alternate or competing things           
          (as persons, purposes, duties) (done solely for money) (a                   
          privilege granted solely to him) (rely solely on oneself).”  Id.            
          at 2168.                                                                    
               The general dictionary definition of “proceeds” encompasses            
          “what is produced by or derived from something (as a sale,                  
          investment, levy, business) by way of total revenue: the total              
          amount brought in: yield, returns; * * * the net profits made on            
          something”.  Id. at 1807.  Black’s Law Dictionary defines                   
          “proceeds” as “The value of land, goods, or investments when                
          converted into money; the amount of money received from a sale.             
          * * * Something received upon selling, exchanging, collecting, or           
          otherwise disposing of collateral.”  Black’s Law Dictionary 1242            
          (8th ed. 2004).                                                             
               Black’s Law Dictionary also provides the following subentry            

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