- 13 - it limited to services performed in January 2002. These are only three examples that reflect a pattern of mismatching of revenue and time spent by nearly all of petitioner’s employees during all months of 2002. The conclusion is inescapable--petitioner’s 2002 revenues do not measure the time spent by petitioner’s employees during 2002. Some of petitioner’s 2002 revenue was received for work done outside of 2002, and petitioner received no revenue during 2002 for some of the work done by its employees during 2002. Finally, petitioner’s 2002 revenue from nonarchitectural services included revenue from “outside consulting”. Mr. Hom testified that outside consulting included “mechanical, electrical engineers, plumbing engineers, that basically since we don’t have those engineers in-house, we consult out for them.” In other words, petitioner received revenue during 2002 for work done by people other than petitioner’s employees. By including revenue from outside consulting, petitioner measured time spent by nonemployees, making petitioner’s estimation of time spent by its employees even more inaccurate. For the above reasons, we find that petitioner failed to prove that less than substantially all of its activities were devoted to the performance of services in the qualifying field of architecture. We sustain respondent’s determination that, during 2002, petitioner was a qualified personal service corporationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007