Medical Emergency Care Associates, S.C., An Illinois Corporation - Page 3

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          proper Federal employment taxes.  Consequently, the only issue              
          presently before the Court is whether petitioner is entitled to             
          relief from employment tax liability pursuant to section 530.               
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue.  For             
          convenience, FICA and FUTA taxes are collectively referred to as            
          employment taxes.                                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner’s principal place of business was in                  
          Chicago, Illinois.                                                          
               Petitioner was an Illinois medical service corporation,                
          incorporated in 1990 to provide emergency medical services to               
          hospitals.  Larry Mitchell, M.D. (Dr. Mitchell), was petitioner’s           
          president and sole shareholder.  Petitioner was involuntarily               
          dissolved by the Illinois Secretary of State as of November 1,              
               On April 15, 1996, Neena Mitchell, the multiple-handicapped            
          daughter of Dr. Mitchell, died after a chronic illness.                     
               During and after 1990, petitioner entered into contracts               
          entitled “Emergency Department Services Agreements” (EDS                    
          Agreements) with several Chicago area hospitals to furnish                  

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