- 18 - Commissioner, 49 F.3d 713 (11th Cir. 1995); Mosteirin v. Commissioner, T.C. Memo. 1995-367; Lozon v. Commissioner, T.C. Memo. 1997-250; and also in Feivor v. Commissioner, T.C. Memo. 1995-107. In the Butts line of cases, the taxpayers were insurance agents, so-called neighborhood office agents, for Allstate. In Feivor, the taxpayer was a district manager for an insurance company. We held that the taxpayer in each case was an independent contractor. We reach the same result in the instant case, and for the same reasons: the circumstances, as a whole, do not demonstrate a sufficient amount of control by Combined to find that petitioner was an employee of the company. In particular, Combined did not exert control over the manner and means in which petitioner carried out his responsibilities. See Hathaway v. Commissioner, T.C. Memo. 1996-389. Petitioner was a district manager; although he sold some insurance, he was primarily engaged in the duties of a district manager. We have found that district managers, on average, earned only about 30 percent of their income from commissions on sales, and we believe that at least 70 percent of petitioner’s duties involved recruiting, hiring, training, and supervising of insurance agents. Petitioner had extensive control over the manner and means of the performance of his responsibilities as district manager. He had very little supervision. He reported only weekly to his superiors and almost never received feedback from them on thePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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