Olde Raleigh Realty Corporation - Page 3




                                        - 2 -                                         
               On November 10, 1999, respondent issued to petitioner a                
          Notice of Determination Concerning Worker Classification Under              
          Section 7436 (notice of determination).  In the notice of                   
          determination, respondent determined:  (1) William Henderson (Mr.           
          Henderson) was an employee of Olde Raleigh Realty Corporation               
          (petitioner) for the tax periods ending December 31, 1995 and               
          1996, for purposes of Federal employment taxes, and (2)                     
          petitioner was not entitled to relief from these taxes as                   
          provided by section 530 of the Revenue Act of 1978, Pub. L. 95-             
          600, 92 Stat. 2885 (section 530 of 1978 Act).  (For convenience,            
          we sometimes use the term “employment taxes” to refer to taxes              
          under the Federal Insurance Contributions Act (FICA-Social                  
          Security taxes) and Federal Unemployment Tax Act (FUTA-                     
          Unemployment taxes)).                                                       
               The proposed Federal employment taxes, additions to tax, and           
          related penalties were detailed in the notice of determination as           
          follows:                                                                    
                            Addition to tax     Accuracy-related penalty              
               Year  Tax      Tax       Sec. 6656        Sec. 6662(a)                 
               1995 FICA   $10,105.01   $505.25        $2,021.00                      
               1995 FUTA   434.00       43.40          86.80                          
               1996 FICA   11,926.09    $596.30        2,385.22                       
               1996 FUTA   434.20       43.42          86.84                          
               After concessions by petitioner that Mr. Henderson should be           
          legally classified as an employee of petitioner for purposes of             
          Federal employment taxes and that petitioner is not entitled to             
          relief under section 530 of the 1978 Act, the issues for decision           






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Last modified: May 25, 2011