| http://www.w3.org/ns/prov#value | - Even before Clackamas was decided, the federal courts of appeals had similarly focused on the actual working relationship between an individual and the partnership when inquiring whether the individual was an employee within the meaning of the ADEA. For instance, in its 1997 decision, Simpson v. Ernst & Young,(8) the Sixth Circuit considered a variety of factors before holding that an accountant d
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