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classification pursuant to section 530 of the Revenue
Act of 1978 with respect to such individual(s). This
determination could result in employment taxes being
assessed against you.
Respondent attached to the notice of determination an
Agreement to Assessment and Collection of Additional Tax and
Acceptance of Overassessment (Excise or Employment Tax) (Form
2504) in which respondent proposed that petitioner consent to
immediate assessment and collection of $53,194.87 in tax,
consisting of the following amounts:
1. $27,814.58 for March 31 to December 31, 1994, under the
FICA, secs. 3101-3125, and for income tax withholding, secs.
3401-3406 and 3509;
2. $22,776.29 for March 31 to December 31, 1995, under the
FICA and for income tax withholding; and
3. $2,604.00 for 1995, under the FUTA, secs. 3301-3311.
The form also proposed that petitioner agree to the
following:
I consent to the immediate assessment and
collection of any additional tax and penalties and
accept any overassessment (decrease in tax and
penalties) shown above, plus any interest provided by
law.
I understand that by signing this agreement, I am
waiving the restrictions on assessment provided in
section 7436(d) and 6213(a) of the Internal Revenue
Code of 1986, and that I will not be able to contest
the issues covered by this agreement in the United
States Tax Court.
Respondent attached to the notice of determination a copy of
Examination Changes -- Federal Unemployment Tax for 1995 (Form
4667), and Employment Tax Examination Changes Report for 1994 and
1995 (Forms 4668), detailing respondent's calculations of the
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