Richard G. and Anne C. Greene - Page 30

                                   - NEXTRECORD  -                                    
          G.   Relationship Petitioner and DFM Believed They Had Created              
               Jerry Burgess, who had worked as the financial comptroller             
          of the DFM for 16 years, testified that the DFM considered its              
          missionaries independent contractors, not employees.  Mr.                   
          Burgess' testimony is supported by the fact that the National               
          Church issued petitioner Form 1099-MISC reflecting nonemployee              
          compensation for services rendered.  Additionally, the fact that            
          Federal income tax was not withheld from petitioner's                       
          compensation is consistent with the DFM's view that petitioner              
          was an independent contractor.                                              
               Petitioner also thought he was an independent contractor, as           
          evidenced by the fact that he reported his foreign ministry                 
          receipts and expenses on Schedule C.                                        
               Because the National Church and petitioner thought that                
          petitioner was an independent contractor, this factor would                 
          support a finding that petitioner was an independent contractor,            
          not an employee.                                                            
          H.   Employee-Type Benefits                                                 
               The DFM offered petitioner access to the MBA pension plan              
          and a health insurance plan.  Petitioner participated in the MBA            
          pension plan and the health insurance plan.  The premiums for               
          petitioner's health insurance and the money transferred into                
          petitioner's MBA account were paid directly from petitioner's               
          account with the DFM.                                                       






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