Joseph M. Grey Public Accountant, P.C. - Page 21

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          (2) relief under section 530 is not available with respect to               
          statutory employees.                                                        
          IV.  Summary                                                                
               We have found that Mr. Grey was an employee of petitioner’s            
          within the meaning of section 3121(d)(1) and that petitioner is             
          not entitled to relief under section 530.  Therefore, petitioner            
          is liable for Federal employment taxes for the periods at issue             
          as set forth in respondent’s notice.                                        
               To reflect the foregoing,                                              

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

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