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Commissioner, 65 T.C. 333, 334 (1975), affd. 565 F.2d 954 (5th
Cir. 1978). The deemed admissions establish the following:
! The nine workers listed in the notice of determination
worked at petitioner’s business location during the years in
issue.
! Petitioner hired, supervised, and paid the workers for
their services.
! Petitioner dictated when, where, and how the workers
performed their services, and petitioner set their work hours.
! Petitioner controlled the amount of time each worker spent
performing services.
! Each worker was employed full time by petitioner and was
restricted from working for another employer.
! The workers provided services on petitioner’s premises and
used petitioner’s tools, materials, and equipment.
! The success or continuation of petitioner’s business
depended upon the performance of the nine workers’ services.
! The workers were regularly paid by the hour, week, or
month; they were not paid by job or on commission, nor did they
realize a profit or loss as a result of their services.
! Both petitioner and the workers had the right to terminate
the relationship.
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