Kevin and Bridget Naughton - Page 13




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          petitioner during the years at issue were DWP employees.                    
          Petitioner was employed on a full-time basis and worked weekly,             
          Mondays through Fridays, from 7:30 a.m. until 4:15 p.m., for DWP            
          during 1996 and 1997.  His hours were controlled by Dr. Miller.             
          Petitioner’s relationship with DWP had been ongoing since 1990.             
          All medical services performed by petitioner for remuneration               
          during the years at issue were performed at DWP facilities.  DWP            
          provided petitioner with medical office space, and petitioner did           
          not pay rent for medical office space.  All supplies used by                
          petitioner in providing medical services were furnished by DWP.             
               Petitioner was paid a salary by DWP during 1996 and 1997.              
          He did not bill patients for the medical services he performed.             
          Petitioner did not make his services as a physician available to            
          the general public during the years at issue, and he performed no           
          services as a physician for remuneration during that period                 
          outside of his relationship with DWP.  He did not have a business           
          license to perform medical services as a sole proprietor in 1996            
          or 1997.                                                                    
               DWP issued to petitioner Forms W-2 for both 1996 and 1997,             
          and withheld Federal income tax, State income tax, Social                   
          Security tax, and Medicare tax.  DWP also paid the employer’s               
          share of Social Security and Medicare taxes with respect to                 
          petitioner’s compensation during those years.                               








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