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On the other hand, although the drywall business did not
require highly technical knowledge, petitioner’s shareholder-
employees developed the skills and methods to accurately bid on
and complete projects within budget. An individual could have
entered the drywall construction business with a mere $300
investment, but there was no guarantee of success. Darle
credibly testified that a number of competitors emerged and
failed since petitioner has been in existence. Petitioner has
been engaged in the drywall business for more than 20 years, and
its success depends on the time-tested skills and judgment of its
key employees. In a competitive industry such as this,
petitioner’s development of business methods and techniques
directly related to its success. The successful execution of
these methods was complex or, at a minimum, difficult. We also
believe that the leanness of petitioner’s management and the
multiple duties each shareholder-employee performed further weigh
against respondent. Consequently, we find this factor to favor
petitioner.
D. General Economic Conditions
Another factor we take into consideration is the employee’s
impact on the corporation’s success compared to the impact of the
general economic conditions. See RTS Inv. Corp. v. Commissioner,
supra at 651. This comparison helps indicate whether the
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