- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007