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that TIG performed computer training and installed networking
cable and telephone systems. As a result, petitioner argues that
he “was not a key connection with customers, only one of many
resources available to them”, and was therefore not an integral
part of TIG’s business. However, the fact that TIG had several
separate divisions does not affect the analysis of whether
petitioner’s services were integral to TIG. Petitioner’s
services could have been integral to the division in which he
worked, which would indicate that petitioner was an employee.
See Ewens & Miller, Inc., v. Commissioner, 117 T.C. at 272-273.
Respondent was silent on the issue. The Court concludes
that this factor is neutral and indicates neither independent
contractor status nor employee status.
6. Permanency of the Relationship
A transitory work relationship may weigh in favor of
independent contractor status. Ewens & Miller, Inc. v.
Commissioner, supra at 273 (citing Herman v. Express Sixty-
Minutes Delivery Serv., Inc., 161 F.3d 299, 305 (5th Cir. 1998)).
The principal’s right to discharge the worker, and the worker’s
right to quit, at any time, is an important factor. Id.
Petitioner’s position at TIG was for renewable 1-year terms. It
was also at will and terminable by either party at any time, with
or without cause or notice, and petitioner was in fact
terminated. The Court concludes that petitioner’s position was
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