Philip T. and Mary Ellen Chaplin - Page 22

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          right to quit upon giving 60 days’ notice.  This factor supports            
          a finding that petitioner was an employee of RHB.                           
               7.   The Provision of Benefits Typical of Those Provided to            
                    Employees                                                         
               RHB trained petitioner.  RHB provided petitioner with                  
          general business liability insurance, workmen’s compensation,               
          unemployment insurance, group life and disability insurance,                
          family health insurance, and subscriptions to professional                  
          publications.  RHB paid for petitioner’s expenses to become a               
          chartered financial analyst and reimbursed petitioner for any               
          work-related travel expenses.  RHB also provided petitioner with            
          a company credit card.  These benefits are typical of those an              
          employer provides to an employee.  This factor supports a finding           
          that petitioner was an employee of RHB.                                     
               8.   Petitioners’ Other Arguments                                      
               Petitioners cite Feivor v. Commissioner, T.C. Memo. 1995-              
          107, for the proposition that the fact a taxpayer reports his               
          business expenses on a Schedule C indicates that he is an                   
          independent contractor and not an employee.  Petitioners draw the           
          conclusion that, because they reported on a Schedule C the                  
          trustee’s fees petitioner received and remitted to FDC,                     
          petitioner acted as an independent contractor and not an employee           
          in providing fiduciary services.  How petitioners treated the               
          trustee’s fees petitioner received and remitted to FDC has no               
          bearing on petitioner’s relationship with RHB.  In fact, while              





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