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decide the correct amounts of employment taxes which relate to
the Secretary’s determination concerning worker classification.
Community Renewal Tax Relief Act of 2000 (CRTRA), Pub. L. 106-
554, sec. 314(f), (g), 114 Stat. 2763A-463; Taxpayer Relief Act
of 1997, Pub. L. 105-34, sec. 1454(a), 111 Stat. 1055. In light
of Congress’s action, petitioner sought to amend the amended
petition to place into dispute, as it had in its original
petition, the amounts of employment taxes, additions to tax, and
penalties determined by respondent. Respondent did not object to
the granting of the motion for leave.
We granted petitioner’s motion for leave and filed the
second amended petition. In the second amended petition, as in
the original petition, petitioner sought a redetermination of the
classification determined by respondent and 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 June 15, 2001, respondent filed an answer to the second
amended petition (second answer). In the second answer,
respondent again affirmatively alleged that Mr. and Mrs. Evans
were employees of petitioner during 1993, 1994, and 1995, and
that petitioner is not entitled to “safe harbor” relief as
provided by section 530 with respect to Mr. and Mrs. Evans’
classification as employees. Respondent affirmatively alleged
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