Veterinary Surgical Consultants, P.C. - Page 18




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                                   ______________                                     
               After the petition was filed in this case, Congress amended            
          section 7436(a) to provide this Court with jurisdiction to                  
          determine the correct amounts of Federal employment taxes that              
          relate to the Secretary’s determination concerning worker                   
          classification.  See Community Renewal Tax Relief Act of 2000               
          (CRTRA), Pub. L. 106-554, sec. 314(f), 114 Stat. 2763A-643.  That           
          amendment was made retroactive to the effective date of section             
          7436(a).  CRTRA sec. 314(g), 114 Stat. 2763A-643.                           
               The parties filed a Stipulation of Settled Issues setting              
          forth the proper amount of Federal employment taxes owed by                 
          petitioner in the event we find that Dr. Sadanaga is petitioner’s           
          employee for purposes of Federal employment taxes (which we do).            
          The amount so stipulated will be reflected in our decision                  
          document.                                                                   
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             for respondent and in accordance         
                                             with the parties’ stipulations           
                                             as to amounts.                           











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