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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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