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Rules of Practice and Procedure.
Respondent issued a Notice of Determination Concerning
Worker Classification Under Section 7436 (notice of
determination), in which respondent determined: (1) Ten
individuals who performed services for Maxi’s Today’s Hair
(Maxi’s) during 1994, and four individuals who performed services
for Maxi’s during 1995 were employees of Maxi’s for purposes of
Federal employment taxes under subtitle C (Employment Taxes and
Collection of Income Tax) of the Internal Revenue Code; (2)
petitioner was not entitled to relief under subsection (a) of
section 530 of the Revenue Act of 1978 (section 530), as
amended,1 Pub. L. 95-600, 92 Stat. 2763, 2885, see sec.
7436(a)(2); and (3) petitioner was liable for additions to tax
under sections 6651(a)(1) and 6656(a).
Therefore, the issues in this case are: (1) Whether the
beauticians identified in the notice of determination were common
law employees of petitioner during 1994 and 1995; and, if so, (2)
whether petitioner is entitled to section 530 relief from
employment taxes stemming from the employment of the beauticians;
and (3) whether petitioner was liable for additions to tax under
sections 6651(a)(1) and 6656(a).
1 Sec. 530 of the Revenue Act of 1978 has been amended by
Pub. L. 96-167, sec. 9(d), 93 Stat. 1278; Pub. L. 96-541, sec. 1,
94 Stat. 3204; Pub. L. 97-248, sec. 269(c), 96 Stat. 552; Pub. L.
99-514, sec. 1706, 100 Stat. 2781; and Pub. L. 104-188, sec.
1122, 110 Stat. 1766.
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Last modified: May 25, 2011