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invoke Section 530, they could not meet its terms. One of the
threshold requirements for obtaining Section 530 relief is that
the taxpayer-employer must have filed all required Federal tax
returns (including information returns) on a basis consistent
with the treatment of the worker as not being an employee. Sec.
530(a)(1)(B). For both 1989 and 1992, the Association failed to
file returns consistent with the treatment of Dr. Pariani as an
independent contractor; the Association did not issue a Form 1099
with respect to any payments made to Dr. Pariani for either year.
Accuracy-Related Penalties
Petitioners bear the burden of proving that the
determinations pursuant to section 6662(a) are erroneous. Rule
142(a). Petitioners introduced no evidence relating to these
determinations. Therefore, they are liable for the accuracy-
related penalties under section 6662(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011