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Dimensions and changes in the way the company was conducting its
business. Furthermore, we simply do not believe that petitioner
did not carefully examine his Form W-2 and consider the amount
of income he reported on his 1999 Federal income tax return in
view of all the changes that occurred with his paychecks during
the disputed pay period.
Because of the inconsistencies in petitioner’s testimony,
we decline to believe him where his testimony conflicts with
other testimony or evidence concerning the terms of the work
between petitioner and New Dimensions. We are not required to
accept at face value a taxpayer’s self-serving and
uncorroborated testimony, particularly where other and better
evidence concerning the point in question is available. Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.
593 (1964); Lewis v. Commissioner, T.C. Memo 1993-635.
We now address the seven factors mentioned above as they
relate to the facts in the present case. As we mentioned above,
these seven factors are not weighed equally, but should be
weighed according to their significance in a particular case.
Aymes v. Bonelli, supra; Youngs v. Commissioner, supra. In the
present case, we are most influenced by the evidence that has
persuaded us that the parties intended to enter into a
principal-independent contractor relationship during the
disputed pay period.
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