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Commissioner, T.C. Memo. 1983-661); see also Weber v.
Commissioner, supra at 390 (noting that where professional
individuals are involved, the control necessarily becomes more
tenuous than the control over nonprofessional employees). We
concluded that the colleges maintained and exercised sufficient
control appropriate to the situation and that the level of
control was sufficient to render the taxpayer an employee of the
colleges. Taking into account other common-law factors set forth
above, we concluded that the taxpayer was an employee of both
colleges. See also Bilenas v. Commissioner, supra (finding that
an untenured, adjunct professor was an employee of a college
rather than an independent contractor in relation to his teaching
activities).
As in Potter v. Commissioner, supra, we are satisfied in
this case that the universities had the authority to exercise,
and exercised, sufficient control over petitioner’s teaching
assignments to support a finding that petitioner was an employee
of the universities. Our conclusion on this point is further
supported by the application of other of the common-law factors
relevant to such determinations. Specifically, we note:
(1) The nature of petitioner’s services to the universities as an
adjunct professor is consistent with the regular business of each
university; (2) petitioner’s compensation for the teaching
assignments was set by contract--the risk of loss from under
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