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taxpayer's work is performed. Weber v. Commissioner, supra at
387. We must consider not only the actual control exercised by
the principal, but also the principal's right of control. Id. at
387-388; Professional & Executive Leasing, Inc. v. Commissioner,
supra at 233-234.
In order for a principal to retain the requisite control
over the details of a taxpayer's work, the principal need not
stand over the taxpayer and direct every move made by that
person. Weber v. Commissioner, supra at 388; Professional &
Executive Leasing, Inc. v. Commissioner, supra at 234. Moreover,
the exact amount of control required to find an employer-employee
relationship varies with different occupations. United States v.
W.M. Webb, Inc., 397 U.S. 179, 192-193 (1970). With respect to
individuals providing professional services, there is a lower
threshold level of control for the purposes of determining the
existence of employee status. Weber v. Commissioner, supra at
388; Professional & Executive Leasing, Inc. v. Commissioner,
supra at 234. In this regard, we have stated: "[T]he control of
an employer over the manner in which professional employees shall
conduct the duties of their positions must necessarily be more
tenuous and general than the control over nonprofessional
employees." James v. Commissioner, 25 T.C. 1296, 1301 (1956).
Petitioners contend that petitioner was not an employee with
respect to his activities at NUS. In so doing, petitioners argue
that NUS and Seton Hall imposed little control over his
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