T.C. Memo. 2003-53
UNITED STATES TAX COURT
WATER-PURE SYSTEMS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11344-01. Filed February 26, 2003.
Joseph H. O’Donnell, Jr., for petitioner.
W. Randolph Shump and Pamela J. Arthur-Gerlach, 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
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