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Petitioner claims that he was classified as an employee for
unemployment insurance purposes by the New York State Department
of Labor with respect to all work that he performed in 1987 and
1989 and also points to the fact that respondent determined that
he received taxable unemployment compensation in 1989. The
documentary evidence submitted by petitioner to corroborate his
claim regarding the New York State Department of Labor falls far
short of doing so. Nothing in these materials indicates what
determination, if any, was made by the Department with respect to
any given employer. Since the parties have agreed that
petitioner worked in part as an employee in 1987 and 1989, and
that petitioner had income in 1988, the fact that petitioner
received unemployment compensation in 1989 is not probative with
respect to whether he rendered some services as an independent
contractor in 1987 and 1989.
With respect to 1987, even if we accept petitioner's
uncorroborated testimony concerning his responsibilities at
Aerospace, we do not believe that he has shown that Aerospace had
control over the "details and means by which * * * [the] result
is [to be] accomplished", sec. 31.3121(d)-1(c)(2), Employment Tax
Regs., such that petitioner was an employee under common-law
principles, particularly given the temporary nature of the
assignment and Aerospace's characterization of the arrangement as
"consulting". With respect to 1989, petitioner's testimony is
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