Raymond Verni Schroeder - Page 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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