- 3 - employees of the company for purposes of Federal employment taxes3 under Subtitle C (Employment Taxes and Collection of Income Tax) of the Internal Revenue Code. The notice of determination further provided that petitioner was not entitled to “safe harbor” relief provided by section 530 of the Revenue Act of 1978, Pub. L. 95-600, 92 Stat. 2763, 2885. Respondent attached to the notice of determination a “Preliminary Calculation of tax and additions to tax”, which set forth the following amounts: (1) $20,154 for January 1 to December 31, 1992, under the Federal Insurance Contributions Act (FICA), ch. 736, secs. 3101-3128, 68A Stat. 415 (1954), and under the income tax withholding provisions of sections 3401-3406; (2) $13,060 for January 1 to December 31, 1992, under the Federal Unemployment Tax Act (FUTA), ch. 736, secs. 3301-3311, 68A Stat. 439 (1954); (3) $1,743 in section 6656 penalties for failure to make timely deposits of taxes; and (4) $24,911 in section 6663 fraud penalties. On September 8, 1998, petitioner filed with the Court a petition seeking our review of the notice of determination.4 In 3 For convenience, we use the term “employment taxes” to refer to taxes under the Federal Insurance Contributions Act (FICA), ch. 736, secs. 3101-3128, 68A Stat. 415 (1954), the Federal Unemployment Tax Act (FUTA), ch. 736, secs. 3301-3311, 68A Stat. 439 (1954), and income tax withholding, secs. 3401- 3406. 4 The petition was actually filed by petitioner and petitioner’s wife, Anne Neely. On May 14, 1999, respondent filed (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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