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determining the substance of an employment relationship some of
the factors to be considered include: (1) The degree of control
exercised by the principal over the details of the work; (2)
which party invests in the facilities used in the work; (3) the
opportunity of the hired party for profit or loss; (4) whether
the type of work is part of the principal's regular business; (5)
the permanency of the relationship between the parties to the
relationship; (6) whether the principal has the right to
discharge the individual; (7) whether the principal provides
benefits to the hired party typical of those provided to
employees; and (8) the relationship the parties believe they are
creating. See Nationwide Mut. Ins. Co. v. Darden, supra at 322-
324; Professional & Executive Leasing, Inc. v. Commissioner,
supra at 232-233; Weber v. Commissioner, supra at 387. No one
factor is determinative; rather, all the incidents of the
relationship must be assessed and weighed. See Nationwide Mut.
Ins. Co. v. Darden, supra at 324.
The principal's right to control the manner in which the
taxpayer's work is performed ordinarily is the single most
important factor in determining whether there is a common-law
employment relationship. See Leavell v. Commissioner, 104 T.C.
140, 149 (1995). However, the principal need not stand over the
taxpayer and direct every move. Moreover, the degree of control
necessary to find employee status varies according to the nature
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