Richard G. and Anne C. Greene - Page 20

                                   - NEXTRECORD  -                                    
          Professional & Executive Leasing, Inc. v. Commissioner, 89 T.C.             
          at 231.  Under section 31.3401(c)-1(b), Employment Tax Regs., an            
          employer-employee relationship--                                            
               Generally * * * exists when the person for whom                        
               services are performed has the right to control and                    
               direct the individual who performs the services, not                   
               only as to the result to be accomplished by the work                   
               but also as to the details and means by which that                     
               result is accomplished.  That is, an employee is                       
               subject to the will and control of the employer not                    
               only as to what shall be done but how it shall be done.                
               * * *  In general, if an individual is subject to the                  
               control or direction of another merely as to the result                
               to be accomplished by the work and not as to the means                 
               and methods for accomplishing the result, he is not an                 
               As a preliminary matter we note that the parties dispute the           
          identity of the principal in applying the control test.                     
          Petitioners contend that in analyzing whether petitioner is an              
          employee, only the control exercised by the DFM should be                   
          considered.  Respondent contends that the DFM is a division of              
          the National Church and that the collective right to control                
          maintained by the DFM and the National Church must be considered.           
               We agree with respondent on this point.  The National Church           
          prosecutes its activities, in part, through general offices such            
          as the DFM.  The DFM is merely an extension of the National                 
          Church charged with the specific task of coordinating Assemblies            
          of God missionary efforts outside the United States.  As an                 
          agency of the National Church, the DFM performs this task on                
          behalf of the National Church.  Thus, we think that the control             
          exercised by both the National Church and the DFM should be                 

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