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very difficult for a lumper to determine his status as either an
employee or an independent contractor. Petitioners cite several
cases which have addressed this issue, some of which conclude the
lumper was an employee, while others conclude the lumper was an
independent contractor. Lanigan Storage & Van Co. v. United
States, 389 F.2d 337 (6th Cir. 1968); McGuire v. United States,
349 F.2d 644 (9th Cir. 1965); Service Trucking Co. v. United
States, 347 F.2d 671 (4th Cir. 1965); R & H Corp. v. United
States, 255 F. Supp. 870 (W.D. Pa. 1966). Petitioners' argument
is not persuasive. Petitioners were put on notice of a possible
problem with petitioner's status as an employee because peti-
tioner never received a Form W-2 from any of the persons or
entities he worked for. Petitioners included with each of their
1981 and 1982 income tax returns a temporary handwritten Form W-2
which petitioner prepared himself. Petitioners give no indica-
tion that they investigated why no Form W-2 was issued to
petitioner or whether the amounts they claimed as withholdings
were in fact withheld. The record contains no evidence that
petitioner, given a good faith effort, would not have been able
to correctly file as an independent contractor. Indeed, there is
no probative evidence regarding the principal's control over the
details of his work, or in regard to any other factor commonly
taken into account to distinguish an employee from an independent
contractor. See, e.g., Walker v. Commissioner, 101 T.C. 537, 542
(1993). Thus, petitioner did not show that his failure to pay
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