-2-
1996, the Court also has jurisdiction by virtue of P’s
dispute as to R’s determination that the other workers
were P’s employees during that year. Held, further,
the disputed amounts are wages. Held, further, P is
not entitled to relief under section 530 of the Revenue
Act of 1978 Pub. L. 95-600, 92 Stat. 2763, 2885. Held,
further, P is liable for the additions to tax
determined by R under secs. 6651(a) and 6656, I.R.C.,
to the extent stated herein.
Robert E. Kovacevich, for petitioner.
Milton B. Blouke, for respondent.
LARO, Judge: Petitioner petitioned the Court under section
7436(a)1 to redetermine the following employment tax liabilities
and additions thereto determined by respondent:
Tax Period Additions to Tax
Ended Employment Tax Sec. 6651(a)(1) Sec. 6656
3/1995 $2,356.20 $589.05 $117.81
6/1995 2,004.30 501.08 100.22
9/1995 1,774.80 443.70 88.74
12/1995 2,627.85 656.96 80.68
3/1996 1,300.50 325.13 65.03
6/1996 2,080.80 520.20 104.04
9/1996 841.50 210.38 42.08
12/1996 2,191.11 212.91 70.27
3/1997 1,942.48 485.62 97.12
6/1997 1,942.48 485.62 97.12
9/1997 1,942.28 -0- 97.12
12/1997 1.942.48 -0- 97.12
3/1998 1,785.89 357.18 89.29
6/1998 2,004.30 -0- 89.29
9/1998 2,004.30 -0- 89.29
12/1998 2,004.30 -0- 89.29
1 Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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