Medical Emergency Care Associates, S.C., An Illinois Corporation - Page 6

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          respondent began an examination of petitioner’s 1996 employment             
          tax liability.  By letter dated January 8, 1999, respondent                 
          notified petitioner of his proposed determinations that                     
          petitioner was not entitled to relief under section 530 and that            
          certain workers should be reclassified as employees, and                    
          respondent listed the attendant adjustments to petitioner’s                 
          Federal employment tax liability for 1996.  On May 14, 1999,                
          respondent provided petitioner with Publication 1976, which                 
          provided written notice of the provisions of section 530.                   
          I.  Section 530 Relief                                                      
               Section 530 operates in enumerated circumstances to afford             
          relief from employment tax liability, notwithstanding the actual            
          relationship between the taxpayer and the individual performing             
          services.  The statute provides, in part:                                   
               SEC. 530.  CONTROVERSIES INVOLVING WHETHER INDIVIDUALS                 
                         ARE EMPLOYEES FOR PURPOSES OF THE EMPLOYMENT                 
               (a) Termination of Certain Employment Tax Liability–-                  
               (1) In general.--If--                                                  
                         (A) for purposes of employment taxes,                        
                    the taxpayer did not treat an individual as                       
                    an employee for any period, and                                   
                         (B) in the case of periods after                             
                    December 31, 1978, all Federal tax returns                        
                    (including information returns) required to                       
                    be filed by the taxpayer with respect to such                     
                    individual for such period are filed on a                         

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