Karl Paul Vossbrinck - Page 7




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          to administratively resolve his employment status had resulted in           
          the decision that the status for the years under consideration              
          were unchanged and hence that the liabilities remained                      
          outstanding and collectible.  We note that although petitioner              
          was advised of the decision that the examination personnel had              
          decided that his employment status was that of employee during              
          November 2000, and of respondent’s determination to proceed with            
          collection during December 2000, petitioner did not begin the               
          process of seeking the private letter ruling until more than                
          1 year later (about 8 days before trial).  Under these                      
          circumstances, we find that petitioner was given a full and fair            
          opportunity to seek an alternative resolution of his tax                    
          liabilities.                                                                
               To reflect the foregoing,                                              
                                             An appropriate decision will             
                                        be entered permitting respondent to           
                                        proceed with collection.                      


















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