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We are sorry, but your offer is rejected because
the tax is held to be legally due and an amount larger
than the offer appears to be collectible. We do not
have authority to accept an offer in these
circumstances.
I. The Notice of Determination
On May 24, 1999, respondent sent to petitioner a Notice of
Determination Concerning Worker Classification Under Section
7436. The notice determined that Mr. Barron should be classified
as an employee for purposes of Federal employment taxes under
subtitle C of the Internal Revenue Code for the calendar quarters
in, and the calendar years of, 1994, 1995, and 1996. The notice
also determined that petitioner was not entitled to treatment
under section 530 of the Revenue Act of 1978 with respect to Mr.
Barron.5
On August 24, 1999, petitioner filed a petition under
section 7436 contesting respondent’s determinations.
5 The determinations made by respondent in the Notice of
Determination reflect petitioner’s liabilities as originally
proposed by respondent’s employment tax agent, described supra in
E.
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Last modified: May 25, 2011