- 21 - (6) Permanency of the Relationship A relationship established to accomplish a specified objective is not indicative of an employment relationship. Ellison v. Commissioner, 55 T.C. at 155. A transitory work relationship may point toward a nonemployee status. Ewens & Miller, Inc. v. Commissioner, supra at 273. Petitioner testified neither he nor i2 contemplated a continuing relationship. He asserted his advisory position began in January 2000 and terminated in October 2000, when his replacement was found. The continued relationship was for a brief period and merely to accomplish a specific objective. This factor indicates an absence of an employee-employer relationship. (7) Relationship the Parties Thought They Created Petitioner argued at trial and in brief that he and Mr. Brady created a new employee-employer relationship before he retired on December 31, 1999, which lasted until October 2000. The record indicates no such relationship was created with i2 after his retirement. An e-mail written by Mr. Brady to i2’s management praising petitioner’s accomplishments stated petitioner’s termination was effective December 31, 1999. In response, i2’s CEO asked Mr. Brady to send the e-mail to all employees of i2. Furthermore, petitioner’s Employee Termination Form and Notice of Right to Convert Life Insurance stated he was terminated on December 31,Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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