Transport Labor Contract/Leasing, Inc. & Subsidiaries - Page 25

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          apart from the services it provided Beech Trucking.”  Id. at 443.           
               In contrast to the record before the Court in Beech Trucking           
          Co., the Court in Transport Labor I had a complete, extensive,              
          and clear record upon which to base its findings and conclusions            
          and which included the exclusive lease agreement, the driver                
          contract, the TLC driver handbook, and the testimony of                     
          representatives of various trucking company clients and TLC.  In            
          addition, there was no evidence, and petitioner does not contend,           
          (1) that petitioner or TLC had any overlapping personnel with any           
          trucking company client, (2) that petitioner or TLC owned any               
          interest in any trucking company client, or (3) that any owner of           
          a trucking company client owned an interest in petitioner.29  Cf.           
          id. at 430-431.  Moreover, in contrast to ATS, which insofar as             
          the record in Beech Trucking Co. revealed had only one trucking             
          company as a client, viz., Beech Trucking Company, id. at 443,              
          during the years at issue TLC had between 100 and 300 trucking              
          company clients, Transp. Labor Contract/Leasing, Inc. & Subs. v.            
          Commissioner, 123 T.C. at 156.  It is mere speculation on the               
          part of petitioner to assume that if the facts in Beech Trucking            
          Co. had been virtually the same as the facts in the instant case,           
          which they are not, the Court in Beech Trucking Co. nevertheless            
          would have evaluated the common-law employment factors in the               

               29TLC was a wholly owned subsidiary of petitioner.  Transp.            
          Labor Contract/Leasing, Inc. & Subs. v. Commissioner, 123 T.C. at           

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