Lisa Beth Levine - Page 19

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          obtained.  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; it is              
          sufficient if he has the right to do so.  Weber v. Commissioner,            
          103 T.C. at 388; Profl. & Executive Leasing, Inc. v.                        
          Commissioner, 89 T.C. at 234; Simpson v. Commissioner, 64 T.C. at           
          985; Gierek v. Commissioner, T.C. Memo. 1993-642.  Similarly, the           
          principal need not set the employee’s hours or supervise every              
          detail of the work environment to control the employee.  Gen.               
          Inv. Corp. v. United States, 823 F.2d 337, 342 (9th Cir. 1987).             
               Mr. Urman was the COR to whom petitioner was directly                  
          responsible.  Mr. Urman assigned projects to petitioner, provided           
          policy guidance, and established general priorities.  Mr. Urman             
          could not, however, alter or modify the personal service                    
          contracts.  Therefore, Mr. Urman could not assign projects that             
          required services other than those delineated in the contracts,             
          change petitioner’s hours, or transfer her to another department.           
               Petitioner was responsible for planning and carrying out the           
          projects delivered under the personal service contracts, with               
          little administrative direction.  She was responsible for the               
          quality and technical accuracy of all services and work product.            
          Petitioner’s completed work was considered technically                      

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