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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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