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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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