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work less. She understood that she would be responsible for
filing her own tax returns and paying her related taxes and that
CTI would not pay or withhold any taxes for her benefit. She
knew her employment status with CTI was changing. On or about
May 24, 2001, petitioner informed CTI’s section 401(k) plan that
she had terminated her employment with CTI on January 12, 2001,
and was electing to roll over her balance in that plan to her
individual retirement account at CIBC Oppenheimer.
After January 12, 2001, petitioner was neither an officer,
director, or 10-percent stockholder of CTI. She continued to
provide CTI with essentially the same types of services that she
had provided to CTI before January 13, 2001, but she worked fewer
hours after January 12, 2001, than she did before, and she was
not paid a salary but was paid in accordance with the hours that
she claimed on the invoices she submitted to CTI. After January
12, 2001, petitioner continued to report to Dr. Bianco, but she
was evaluated through verbal feedback and not as formally as
before. After January 12, 2001, she also could hire or
subcontract third parties to perform most of the services listed
in the consultation agreement, and she could have worked for
companies other than CTI. After August 2001, petitioner no
longer headed or was responsible for CTI’s human resource
department.
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Last modified: November 10, 2007