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importance, though not exclusive. See Atlantic Coast Life Ins.
Co. v. United States, 76 F. Supp. 627, 630 (E.D.S.C. 1948). We
must examine both the right of control and the control actually
exercised by the potential employer. See Radio City Music Hall
Corp. v. United States, 135 F.2d 715, 717 (2d Cir. 1943);
deTorres v. Commissioner, T.C. Memo. 1993-161. The amount of
control necessary to find an employer-employee relationship
varies with different occupations. See United States v. W.M.
Webb, Inc., 397 U.S. 179, 192-193 (1970); Reece v. Commissioner,
T.C. Memo. 1992-335.
We discuss below the factors considered to decide whether
petitioner was a common-law employee or an independent
contractor.
A. Degree of Control
IBC controlled the extent of petitioner’s territory. IBC
required that petitioner deliver goods to certain customers on
specific days of the week. IBC dictated the hours of work,
compensation, and leave. IBC required petitioner to punch a time
clock when he began and ended a workday at IBC’s place of
business. Petitioner needed IBC’s permission to take leave.
B. Investment in Facilities
IBC paid for and supplied the goods petitioner delivered.
IBC provided petitioner with his delivery vehicle, and IBC paid
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