7
principles to the particular circumstances presented. Secs.
1402(d), 3121(d)(2); Nationwide Mut. Ins. Co. v. Darden, 503 U.S.
318 (1992). Factors that are relevant in determining whether an
individual is a common-law employee include: (1) The degree of
control exercised by the principal over the details of the work;
(2) the individual's investment in the work facilities; (3) the
individual's opportunity for profit or loss; (4) the permanency
of the relationship between the parties; (5) the principal's
right to discharge the individual; (6) whether the work is an
integral part of the principal's business; (7) the relationship
that the parties think that they are creating; and (8) whether
fringe benefits are provided. NLRB v. United Ins. Co. of Am.,
390 U.S. 254, 258 (1968); Weber v. Commissioner, 103 T.C. 378,
387 (1994), affd. 60 F.3d 1104 (4th Cir. 1995). Although no one
factor is controlling, the degree of the principal's control over
the details of the work is the most important factor. Weber v.
Commissioner, supra at 387. An employer generally has the right
to control not only the result to be accomplished, but also the
details and means by which it is accomplished. Sec. 31.3401(c)-
1(b), Employment Tax Regs.
Although the record is scant, several of the factors tend to
indicate that petitioner was an independent contractor. Astron
did not control or direct petitioner in his activities. In
addition, Astron did not provide petitioner with any fringe
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