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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 corporation
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