Richard G. and Anne C. Greene - Page 27

                                   - NEXTRECORD  -                                    
          support a finding that petitioner was an independent contractor,            
          not an employee.                                                            
          B.   Investment in Facilities and Equipment                                 
               Petitioner's sole compensation as a missionary was in the              
          form of a "personal allowance" secured from funds that he raised            
          during his deputational ministry.  In this regard, we observe               
          that if a donor fails to remit a pledged amount, the DFM makes no           
          effort to contact the donor, much less obtain the donation.                 
          Additionally, the National Church does not guarantee missionaries           
          minimum compensation or support.  Petitioner used his personal              
          car and telephone to raise funds during his deputational                    
          ministry.  Petitioner occasionally hired assistants at his own              
          discretion and accepted responsibility for paying those                     
          assistants.                                                                 
               Respondent contends that petitioner was reimbursed for his             
          expenses when he withheld costs from the offerings remitted to              
          the DFM.  Even if petitioner were regarded as receiving                     
          reimbursement for his expenses, this matter is more than                    
          outweighed by other evidence probative of his being an                      
          independent contractor, e.g., petitioner's efforts in securing              
          the funding for his foreign ministry and his investment in his              
          automobile and telephone.  Thus, this factor supports a finding             
          that petitioner was an independent contractor, not an employee.             








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