Flash -- There is something fishy going on with that requirement. Just because you have an EIN doesn't mean that'll absolve TS from calling employees ICs. There are requirements that need to be met to call someone an IC. So, I would imagine that even if all of their shoppers had EINs, if they are telling them the time they have to be at the location (not a window of time), the time they have to leave the location (not how long they have to stay at the location) and exactly how to do the shop, as opposed to guidelines with information you need to gather, they may still be in trouble.