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owed by petitioner for 1993, 1994, and 1995. Respondent also
determined additions to tax pursuant to section 6651(a)(1) and
penalties pursuant to section 6662.
On July 27, 2000, petitioner petitioned this Court.
Petitioner disputed that its sales personnel and graphics
personnel should have been treated as employees rather than
independent contractors; i.e., petitioner sought a
redetermination of the classification determined by respondent.
Petitioner also disputed the amounts of the employment taxes,
additions to tax, and penalties that were set forth on the
schedule accompanying the notice of determination.
On September 26, 2000, respondent filed a Motion to Dismiss
for Lack of Jurisdiction and to Strike as to the Amounts of
Employment Taxes Proposed for Assessment by the Respondent
(motion to dismiss). Respondent sought to dismiss issues
regarding the amounts of the employment taxes, the additions to
tax, and the penalties and to strike from the petition references
to the amounts of petitioner’s employment tax. Respondent relied
on our decision in Henry Randolph Consulting v. Commissioner, 112
T.C. 1 (1999) (holding that we did not have jurisdiction to
decide the amount of employment tax liabilities).
On October 17, 2000, petitioner filed a response to
2(...continued)
68A Stat. 439 (1954), and income tax withholding, secs. 3401-
3406.
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