Wow. There's some mighty thin reasoning in that document. They cite three factors to overcome their 10-part common law test. I guess that worked for them but it sure looks to me like they're arguing from a conclusion instead of toward one.
What's fun is when the NLRB and the IRS disagree. It's been a couple of decades so I'm working from memory but IIRC the IRS uses a test that breaks the common law factors into about 50 separate questions via Form SS-8.
I wonder if any Uber drivers have gotten anywhere with the IRS by filing an SS-8. That sure would be interesting.