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This Court looks to seven factors to determine the existence
of a common-law employer/employee versus an independent
contractor relationship: (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 individual for profit or loss; (4) whether the principal
has the right to discharge the individual; (5) whether the work
is an integral part of the principal’s regular business; (6) the
permanency of the relationship; and (7) the relationship the
parties believe they are creating. See Weber v. Commissioner,
103 T.C. 378, 387 (1994), affd. per curiam 60 F.3d 1104 (4th Cir.
1995); Professional & Executive Leasing, Inc. v. Commissioner, 89
T.C. at 232; Simpson v. Commissioner, 64 T.C. 974, 984-985
(1975); see also United States v. Silk, 331 U.S. 704, 716 (1947).
No single factor is dispositive, and we must look at all the
facts and circumstances in each case. See Professional &
Executive Leasing, Inc. v. Commissioner, supra at 232; Simpson v.
Commissioner, supra at 985; Eren v. Commissioner, T.C. Memo.
1995-555, affd. 180 F.3d 594 (4th Cir. 1999).
Although we review all of the factors, the “right to
control” is the crucial factor in determining the nature of a
working relationship. Weber v. Commissioner, supra at 387;
Matthews v. Commissioner, 92 T.C. 351, 361 (1989), affd. 907 F.2d
1173 (D.C. Cir. 1990). The degree of control is one of great
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