Calpo Hom & Dong Architects, Inc. - Page 13




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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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