Richard G. and Anne C. Greene - Page 21

                                   - NEXTRECORD  -                                    
          considered together in determining whether petitioner is an                 
               Respondent contends that the DFM exercised control, or had             
          the right to exercise control, over petitioner to such a degree             
          that we must conclude that he was an employee.  In this regard,             
          respondent points out that as a missionary, petitioner qualifies            
          as a professional who required little supervision and that the              
          absence of actual control should not be confused with an absence            
          of the right to control.                                                    
               The threshold level of control necessary to find employee              
          status is generally lower when applied to professional services             
          than when applied to nonprofessional services.  Azad v. United              
          States, supra at 77, Professional & Executive Leasing, Inc. v.              
          Commissioner, 89 T.C. at 232.  However, the precise degree of               
          control required to find an employer-employee relationship varies           
          with different occupations.  United States v. W.M. Webb, Inc.,              
          397 U.S. 179, 193 (1970).  In the present case, even applying a             
          lower standard of control because of petitioner's status as a               
          professional, we find that neither the National Church nor the              
          DFM exercised, or had the right to exercise, a sufficient degree            
          of control to support a finding that petitioner was an employee.            
               Neither the National Church nor the DFM provided any type of           
          professional training for petitioner.  The DFM did not assign               
          petitioner to minister in a particular country; petitioner                  
          selected Bangladesh, notwithstanding the reservations expressed             

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