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(Smith) and Teanna Mawson (Mawson) were employees of petitioner
for Federal employment tax purposes during 1993 through 1997;
whether petitioner is subject to the addition to tax for failure
to file Forms 941, Employer’s Quarterly Federal Tax Return, as
required under section 6651 for all four quarters of each of the
years in issue; and whether petitioner is subject to the addition
to tax for failure to make a deposit of FICA taxes as required
under section 6656 for the years in issue. Petitioner concedes
that he is not entitled to relief under section 530 of the
Revenue Act of 1978, Pub. L. 95-600, 92 Stat. 2885, as amended,
and he has not sought relief under section 3509, relating to the
wages paid during any of the four quarters of each of the years
in issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner’s principal place of business was in Bakersfield,
California, at the time the petition was filed.
In 1985, petitioner began practicing law as a licensed
attorney in California. From 1985 through 1993, petitioner
worked for private law firms in California on litigation matters.
While working with the law firm Young Wooldridge, petitioner met
Smith and trained her in spelling, typing, and court procedure.
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