Shawnee E. Tefteller - Page 8




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          parties, including:  (1) The degree of control exercised by the             
          principal; (2) which party invests in work facilities used by the           
          individual; (3) the opportunity of the individual for profit or             
          loss; (4) whether the principal can 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 believed they were creating.  See id.  All the facts and            
          circumstances of each case should be considered.  See id.                   
               The right of control is ordinarily the crucial factor in               
          determining whether an employer-employee relationship exists.               
          See Matthews v. Commissioner, 92 T.C. 351, 361 (1989), affd. 907            
          F.2d 1173 (D.C. Cir. 1990).  To retain the requisite control over           
          the details of an individual’s work, the principal need not stand           
          over the individual and direct every move made by the individual.           
          See Weber v. Commissioner, supra at 388.                                    
               Petitioner failed to establish that she had sufficient                 
          control over the type of work or services she performed for Mr.             
          Gans and his related businesses at the time the services were               
          rendered to be classified as an independent contractor.  There is           
          scant evidence in this case besides petitioner’s own testimony.             
          It is well settled that we are not required to accept a                     
          taxpayer’s self-serving testimony in the absence of corroborating           
          evidence.  See Niedringhaus v. Commissioner, 99 T.C. 202, 212               
          (1992).  Furthermore, the record is unclear as to the nature of             






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