T.C. Memo. 2002-118
UNITED STATES TAX COURT
DENNIS KATZ, D.D.S., P.C., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8498-00. Filed May 14, 2002.
Elizabeth J. Atkinson, for petitioner.
Sandra M. Jefferson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge: This is an employment status
determination case brought pursuant to section 7436.1 On May 9,
2000, respondent mailed to petitioner a Notice of Determination
Concerning Worker Classification under section 7436, in which it
was determined that, during the taxable years 1996 and 1997,
Dennis Katz was a statutory employee of petitioner and petitioner
1 Except with reference to sec. 530 of the Revenue Act of 1978,
Pub. L. 95-600, 92 Stat. 2885, section references are to the
Internal Revenue Code applicable to the years in question.
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