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          to decide the total amount of wages of each individual who the              
          Commissioner determined, or alleged in the answer, to be an                 
          employee of the taxpayer.                                                   
          II. Motion To Strike                                                        
               Rule 290(a) provides:                                                  
                    (a) Applicability:  The Rules of this Title XXVIII                
               set forth the provisions which apply to actions for                    
               redetermination of employment status under Code Section                
               7436.  Except as otherwise provided in this Title, the                 
               other Rules of Practice and Procedure of the Court, to                 
               the extent pertinent, are applicable to such actions                   
               for redetermination.                                                   
          Title XXVIII does not set forth specific rules regarding motions            
          to strike.  See Rules 290-295.  Accordingly, we apply Rule 52 and           
          the case law thereunder in determining whether to grant or deny             
          the motion to strike.  See Liberty Ministries Intl. v.                      
          Commissioner, T.C. Memo. 1984-260 (applying Rule 52, via Rule               
          210, in the context of an action for declaratory judgment).                 
               Rule 52 provides that this Court, upon a timely motion of              
          the parties or on its own initiative, may strike from any                   
          pleading any insufficient claim or defense or any redundant,                
          immaterial, impertinent, frivolous, or scandalous matter.  Rule             
          52 was derived from rule 12(f), Federal Rules of Civil Procedure.           
          Estate of Jephson v. Commissioner, 81 T.C. 999, 1000 (1983);                
          Allen v. Commissioner, 71 T.C. 577, 579 (1979).  Accordingly, the           
          principles enunciated by the Federal courts in the interpretation           
          and application of that provision are applicable here.  Estate of           






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