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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; Weber v. Commissioner, supra at
387; Professional & Executive Leasing, Inc. v. Commissioner,
supra at 232. The factors are not necessarily weighed equally,
but according to their significance in the particular case. See
Aymes v. Bonelli, 980 F.2d 857, 861 (2d Cir. 1992); Matt v.
Commissioner, T.C. Memo. 1990-209; see also sec. 31.3401(c)-1(d),
Employment Tax Regs.
Ordinarily, the principal’s right to control the manner in
which the work is performed is the single most important factor
in determining whether there is an employer-employee
relationship. See Leavell v. Commissioner, 104 T.C. 140, 149
(1995). In this regard, petitioners point out that petitioner
was free to teach his classes and supervise his thesis and
special topic students as he deemed appropriate. Petitioners
also point out that, other than the time spent teaching students
in the classroom, petitioner was required to spend very little
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