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Tax Act (FUTA) for 1996, 1997, and 1998. The issues for decision
are: (1) Whether Martin L. Ridge (Ridge) was an employee of
petitioner for Federal employment tax purposes during 1996
through 1998 and, if so, (2) whether petitioner is entitled to
relief under section 530 of the Revenue Act of 1978, Pub. L. 95-
600, 92 Stat. 2885, as amended (Section 530).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. For convenience, FICA and FUTA taxes are collectively
referred to as employment taxes.
FINDINGS OF FACT
The facts in this matter were deemed stipulated pursuant to
Rule 91(f). The stipulated facts are incorporated in our
findings by this reference.
Petitioner’s Organization and Operations
Petitioner was incorporated in Pennsylvania on July 19,
1985, and has at all relevant times operated as an S corporation.
Petitioner’s principal place of business was located in
Langhorne, Pennsylvania, at the address of Ridge’s personal
residence, when the petition was filed in this case.
Since its organization and through the years in issue,
petitioner provided sales and service of water purification
systems. This activity was petitioner’s only business and only
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