112 T.C. No. 1
UNITED STATES TAX COURT
HENRY RANDOLPH CONSULTING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6838-98. Filed January 6, 1999.
R determined, in a notice mailed to P,
that some of P's workers were employees and
that P was not eligible for relief under sec.
530 of the Revenue Act of 1978, Pub. L. 95-
600, 92 Stat. 2763, 3855, for certain taxable
periods. R attached to the notice a proposed
agreement to assessment of tax resulting from
R's determination. P filed a petition
seeking our redetermination under sec. 7436,
I.R.C., of R's determination, including the
amounts of tax R proposed to assess.
Held: We lack jurisdiction to decide
the amount of P's employment tax and income
tax withholding liability for the taxable
periods in issue.
George W. Connelley, Jr., Linda S. Paine, and
William O. Grimsinger, for petitioner.
M. Kathryn Bellis, for respondent.
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