- 2 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011