Ertan and Susan Eren - Page 12

                                                  -12-                                                     
            be examined.  Radio City Music Hall Corp. v. United States, 135                                
            F.2d 715, 717 (2d Cir. 1943); deTorres v. Commissioner, T.C. Memo.                             
            1993-161.  "[N]o actual control need be exercised, as long as the                              
            employer has the right to control."  Professional & Executive                                  
            Leasing, Inc. v. Commissioner, 862 F.2d at 753.  In order for an                               
            employer to retain the requisite control over the details of an                                
            employee's work, the employer need not direct each step taken by                               
            the employee.   Professional  &  Executive  Leasing,  Inc.  v.                                 
            Commissioner, 89 T.C. at 234; Gierek v. Commissioner, T.C. Memo.                               
            1993-642.  The exact amount of control required to find an                                     
            employer-employee relationship varies with different occupations.                              
            United States v. W. M. Webb, Inc., 397 U.S. 179, 192-193 (1970).                               
            In fact, the threshold level of control necessary to find employee                             
            status is in most circumstances lower when applied to professional                             
            services than when applied to nonprofessional services.  Azad v.                               
            United States, 388 F.2d 74, 77 (8th Cir. 1968); Professional and                               
            Executive Leasing, Inc. v. Commissioner, supra at 234.  "From the                              
            very nature of the services rendered by * * * professionals, it                                
            would be wholly unrealistic to suggest that an employer should                                 
            undertake the task of controlling the manner in which the                                      
            professional conducts his activities."  Azad v. United States,                                 
            supra; Weber v. Commissioner, 103 T.C. at 388.  An alleged                                     
            employer's control "must necessarily be more tenuous and general                               








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