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The degree of control exercised by the principal over the details
of the work; (2) which parties invest 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 part of the principal’s
regular business; (6) the permanency of the relationship; and (7)
the relationship the parties believe they are creating. Simpson
v. Commissioner, 64 T.C. 974, 984-985 (1975) (and cases cited
therein); Steffens v. Commissioner, T.C. Memo. 1984-592. No one
factor is controlling. Where a sole shareholder controls and
provides services to the corporation the element of control
becomes less relevant. Jacobs v. Commissioner, supra; Rev. Rul.
71-86, 1971-1 C.B. 285.
As explained supra, Mr. Robinson was involved in the day-to
day operations of the aircraft brokerage business. Mrs. Robinson
was involved in the day-to-day administrative details of Career.
Mrs. Robinson, along with two others, prepared corporate checks
and coded them for posting to the general ledger. She was also
responsible for marketing. Significantly, Mrs. Robinson was the
primary dispatcher for the freight and passenger charter
activities, including the coordination and readying of the planes
and crew for the freight and charter businesses. Although Mrs.
Robinson was also the property manager for their significant real
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