- 2 - 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 onlyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011