T.C. Memo. 2003-50
UNITED STATES TAX COURT
SUPERIOR PROSIDE, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4804-00. Filed February 26, 2003.
Joseph H. O’Donnell, Jr., for petitioner.
Linda P. Azmon, 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 (notice of determination)
regarding petitioner’s liabilities pursuant to the Federal
Insurance Contributions Act (FICA) and the Federal Unemployment
Tax Act (FUTA) for 1995, 1996, and 1997. The issues for decision
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