-12-
Oct. 10 1,000
16 700
20 550
Nov. 6 1,400
13 625
17 1,550
Dec. 13 1,100
6,925
As to the amounts that petitioner reportedly paid to Ms.
Odell as wages, petitioner timely filed with the Commissioner
Forms 941 for the calendar quarters ended December 31, 1996,
September 30, 1997, December 31, 1997, June 30, 1998,
September 30, 1998, and December 31, 1998, and filed untimely on
August 2, 1998, a Form 941 for the calendar quarter ended
March 31, 1998. Petitioner did not file a Form 941 for any of
the other calendar quarters during the subject years. In
chronological order, the Forms 941 filed with the Commissioner
reported that petitioner paid the following amount of wages to
one employee during the corresponding quarter: $2,000, 0,
$4,800, $1,200, $1,200, $1,200, and $1,200.
On January 26, 2001, respondent issued to petitioner a
Notice of Determination Concerning Worker Classification Under
Section 7436 (notice of determination) for 1995, 1996, 1997, and
1998. The notice of determination stated in relevant part:
As a result of an employment tax audit, we are
sending you this NOTICE OF DETERMINATION CONCERNING
WORKER CLASSIFICATION UNDER SECTION 7436. We have
determined that the individual(s) listed or described
on the attached schedule are to be legally classified
as employees for purposes of federal employment taxes
under subtitle C of the Internal Revenue Code and that
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