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          detailing respondent's wage adjustments for “4 employees” (1994)             
          and “6 employees” (1995) and included calculations of the amounts            
          to be assessed.                                                              
               After the Court granted respondent's Motion to Dismiss for              
          Lack of Jurisdiction and to Strike as to the Amounts of                      
          Employment Taxes Proposed for Assessment by the Respondent,                  
          respondent's Answer was filed.  Attached to the Answer was a list            
          of individuals that respondent determined should be reclassified             
          as employees of petitioner.  Petitioner then filed its motion,               
          arguing that the notice is invalid because the list of                       
          individuals was not part of the notice of determination sent to              
          petitioner in March 1998.  Petitioner asserts: "The shortcoming              
          is tantamount to failure to specify the amount of the determined             
          deficiency anywhere in a Notice of Deficiency in a case under                
          I.R.C. Section 6212."                                                        
               Respondent argues that the standard to be applied to a                  
          notice of determination is whether it advises the taxpayer that              
          respondent has determined that, for specified time periods, some             
          or all of its workers are to be reclassified as employees and                
          that the notice in this case meets that standard.  Respondent                
          acknowledges that petitioner's analogy between the notice of                 
          determination and a notice of deficiency is reasonable inasmuch              
          as the form of neither is prescribed by statute.  Respondent                 
          contends, however, that petitioner overreaches the scope of the              





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