T.C. Memo. 2003-265
UNITED STATES TAX COURT
FREDERICK C. KUMPEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14339-01. Filed September 10, 2003.
Frederick C. Kumpel, pro se.
Milton B. Blouke, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Worker
Classification Under Section 7436 regarding petitioner’s
liabilities pursuant to the Federal Insurance Contributions Act
(FICA) and the Federal Unemployment Tax Act for 1993, 1994, 1995,
1996, and 1997. The issues for decision are whether Nanci Smith
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