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these courses were conducted on campus in classrooms provided by
the universities. Petitioner prepared for classes and reviewed
student assignments from his home. He communicated with and
received assignments from his students through e-mail on his home
computer, and he maintained a website on the Internet devoted to
his teaching activities at the universities.
In addition to his course responsibilities, as an adjunct
professor, petitioner also supervised a thesis student and a
special topic student at UOI during 1997. Petitioner
communicated with these students primarily through e-mail and
various off-campus meeting places.
All of petitioner’s teaching assignments during 1997 were
subject to written contracts between himself and the
universities. Among other things, each contract specified the
course to be taught or student to be supervised, the duration of
the assignment, and the amount and method of payment. Each
contract also indicated that petitioner would be treated as an
employee of the university, albeit at least with respect to UOI,
the contract provided that petitioner enjoyed “very limited
[employee] benefits”.
For 1997, each university issued to petitioner a Form W-2,
Wage and Tax Statement, reflecting the amounts paid to petitioner
for his services. Both Forms W-2 classified amounts paid to
petitioner as wages. Each university also withheld Social
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