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Form W-2 issued to Mr. Barron for 1994, and petitioner computed
its liability for FUTA tax accordingly.
Except for the $2,000 amount reported as wages on the Form
W-2 issued to Mr. Barron for 1994, which amount was reported on
Form 940 for 1994, petitioner did not include any amount in
respect of Mr. Barron on Form 940 for 1994, 1995, or 1996.
E. Employment Tax Examination
In 1997, respondent commenced an examination of petitioner’s
employment tax liabilities.
In May 1997, petitioner executed Form SS-10 (Consent to
Extend the Time to Assess Employment Taxes), agreeing to extend
through July 31, 1998, the period of limitations for assessing
additional FUTA tax liability reportable on Form 940 for the
calendar year 1994. Respondent executed the consent in June
1997.
In February 1998, petitioner executed another Form SS-10,
this time agreeing to extend through April 15, 1999, the period
of limitations for assessing (1) additional FUTA tax liability
reportable on Form 940 for the calendar year 1994 and (2)
additional employment tax liabilities reportable on Form 941 for
each of the four calendar quarters of 1994. Respondent also
executed the consent in February 1998.
Based on statistical data compiled by Robert Half
International, Inc., respondent’s employment tax agent proposed
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