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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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