Facts
The Principal engaged a Secretarial Service to provide confidential services such as production of letters for a particular client.
The Secretarial Service is operated by the taxpayer as a sole trader.
The Principal engaged the Secretarial Service through an advertisement in a newspaper.
The Secretarial Service performs the duties at the office of the Principal because the matters are confidential and letters are required to be on the Principal's letterhead.
The Secretarial Service has the right to refuse work.
The Secretarial Service can engage persons other than the taxpayer to perform the duties required under the contract. There is no restriction on who does the work.
There are no set hours for the work to be performed. Actual hours worked have varied from four to ten hours per week.
The Secretarial Service invoices the Principal for the work performed. The invoice details each individual task done.