Shawnee E. Tefteller - Page 10




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          Franchise Business International).                                          
               Petitioner next argues that having the right to pick and               
          choose the jobs of her choice demonstrates she had control over             
          her services.  However, petitioner failed to establish the                  
          details of control she had over any job.  For instance,                     
          petitioner’s services were negotiated in contracts with Mr. Gans            
          and his related businesses, but she failed to produce the                   
          contracts at trial.  Without the contracts in the record for our            
          review, we cannot assume that petitioner had the requisite                  
          control over her services.                                                  
               Finally, petitioner’s argument that consulting for a number            
          of companies demonstrates a lack of continuity in the employer-             
          employee relationship is without merit.  In Kelly v.                        
          Commissioner, T.C. Memo. 1999-140, this Court found that working            
          for a number of employers during a tax year does not necessitate            
          treatment as an independent contractor.                                     
               Petitioner’s failure to establish a record with any                    
          corroborating evidence militates against her case.  Without the             
          contracts before us, between either petitioner and Mr. Gans and             
          his related businesses or petitioner and other companies (i.e.,             
          Avante Studios), we cannot find that their provisions corroborate           
          petitioner’s claim that she was an independent contractor.  In              
          sum, petitioner has not demonstrated that she is entitled to                
          treatment as an independent contractor.  Consequently, we find              






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