Laverne S. VanZant - Page 6

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          requirements of section 3121(d)(3)(C) because she did not receive           
          materials or goods from ALS.                                                
               Neither the code nor regulations provide guidance on the               
          meaning of “materials” or “goods”.  Yet, materials are typically            
          the “tools or apparatus for the performance of a given task”.               
          See The American Heritage Dictionary of the English Language 1079           
          (4th ed. 2006).  Petitioner was required to use the ALS template            
          to perform her duties.  The ALS template is, therefore, a                   
          material.  Because the template falls within the definition of              
          materials, we need not consider whether it falls within the                 
          definition of goods.  As noted before, petitioner was required to           
          return the template to ALS.  Thus, petitioner performed services            
          on materials or goods furnished by such person, which are                   
          required to be returned to such person.  Further, petitioner’s              
          services were not performed as a single transaction, and                    
          petitioner did not have a substantial investment in the                     
          facilities (i.e., the schools) used in connection with the                  
          performance of the services.  Accordingly, petitioner was a “home           
          worker” within in the meaning of section 3121(d)(3)(C), and                 
          therefore, a statutory employee exempt from self-employment taxes           
          pursuant to section 1402(c)(2).                                             
               We must also determine whether petitioner is liable for the            
          section 6651(a)(1) addition to tax.  Section 6651(a)(1) provides            

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