- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011