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Darden, 503 U.S. 318, 323-324 (1992); Matthews v. Commissioner,
92 T.C. 351, 360 (1989), affd. 907 F.2d 1173 (D.C. Cir. 1990);
Professional & Executive Leasing, Inc. v. Commissioner, 89 T.C.
225, 232 (1987), affd. 862 F.2d 751 (9th Cir. 1988).
Courts look to several factors to decide whether an
employment relationship exists. Among them are the following:
(1) The degree of control exercised by the principal over the
manner in which work is performed; (2) the individual's
investment in the facilities used; (3) the individual's
opportunity for profit or loss; (4) whether or not the principal
has the right to discharge the individual; (5) the permanency of
the relationship; (6) whether the work performed is an integral
part of the principal's regular business; and (7) the
relationship the parties believe they are creating. United
States v. Silk, 331 U.S. 704, 716 (1947); Simpson v.
Commissioner, 64 T.C. 974, 984-985 (1975); sec. 31.3121(d)-
1(c)(2), Employment Tax Regs. These factors are not weighted
equally but must be evaluated according to their significance in
each particular case. See Packard v. Commissioner, 63 T.C. 621,
630 (1975).
Although no one factor is dispositive, the employer's degree
of control over the details of an individual's work is the most
important consideration in determining the nature of the working
relationship. E.g., Matthews v. Commissioner, supra at 361. An
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