T.C. Memo. 2003-162
UNITED STATES TAX COURT
WESTERN MANAGEMENT, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12686-99. Filed June 3, 2003.
Robert E. Kovacevich and Richard W. Kochansky, for
petitioner.
Milton B. Blouke and Roger P. Law, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Worker
Classification Under Section 74361 (notice of determination)
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
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