Lucien Joseph Larvadain - Page 4

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         contractor providing navigational services and, in particular,               
         training NOAA employees at the U.S. Coast Guard branch facility              
         at Silver Spring, Maryland.  Petitioner was not engaged with NOAA            
         as an employee.  His relationship was based on a contract for                
         training new employees, preparation of manuals, desk reference               
         guides, and other navigational matters used by such employees.               
         Petitioner was not required to be at NOAA offices on a daily                 
         basis and was allowed to prepare his manuals, guides, and other              
         contract requirements at home.  The time petitioner spent at NOAA            
         facilities was to train employees.  However, NOAA made available             
         to petitioner at all times office space and equipment necessary              
         for him to perform his services under the contract.  Petitioner              
         estimated that during the year at issue, he was at NOAA                      
         facilities between 35 and 40 percent of the time for the training            
         of NOAA employees.  The remainder of his time was spent at home              
         where he performed his other obligations under the contract                  
         (preparing training manuals, etc.).  None of the training                    
         activities took place at his home.                                           
              Petitioner’s contract with NOAA was obtained by bid.  He was            
         paid by the hour.  For the year at issue, petitioner contracted              
         to perform 976 hours of work which translated to 122 work days.              
         The compensation for that amount of time was $30,256.3                       

               3  On his income tax return for the year at issue,                     
          petitioner reported $35,222 of income from NOAA.  There is no               

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Last modified: March 27, 2008