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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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Last modified: May 25, 2011