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considered together in determining whether petitioner is an
employee.
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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