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relationship; (7) the relationship the parties believe they are
creating; and (8) whether fringe benefits are provided. Weber v.
Commissioner, supra at 387; Lozon v. Commissioner, T.C. Memo.
1997-250. Other relevant factors are (9) the degree of skill
required on the part of the worker, and (10) whether the worker
makes his services available to more than one company and to the
general public. Breaux & Daigle, Inc. v. United States, supra at
51; Jacobs v. Commissioner, supra.
In this case, the degree of control exercised by the
principal is of little or no relevance since the worker, Dr.
Pariani, is president and sole shareholder and therefore controls
the principal, the Association. Jacobs v. Commissioner, supra.
On the basis of the remaining factors, we conclude that Dr.
Pariani was an employee rather than an independent contractor.
Dr. Pariani had a permanent relationship with the Association.
The Association's line of business was the provision of medical
services, and the work Dr. Pariani performed was not just part of
this line of business but coterminous with it. Dr. Pariani was
integral to the Association's business; in 1992, his compensation
for medical services was over four times as great as the
compensation paid to all other providers of medical services.
His services were essential to the Association. See Weber v.
Commissioner, supra at 391; Jacobs v. Commissioner, supra.
Although he was not the sole provider of medical services, he was
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