- 5 -
determination was a schedule setting forth petitioner’s
liabilities as follows:
Addition to Tax Penalty
Year Deficiency Sec. 6656 Sec. 6662
1994 $48,968 $611 $9,794
1995 14,397 254 3,133
On September 21, 1999, the Court filed respondent’s Motion
To Dismiss In Part For Lack Of Jurisdiction And To Strike As To
The Amounts Of Employment Taxes And Additions To Tax Proposed For
Assessment By The Respondent (partial motion to dismiss). On
October 12, 1999, the Court filed petitioner’s response to the
motion and granted the motion on October 14, 1999. On October
17, 2000, the Court filed petitioner’s Motion To Dismiss For Lack
Of Jurisdiction And Judgment On The Pleadings (motion to
dismiss). On October 17 and 18, 2000, the Court held proceedings
to determine whether petitioner properly classified Kovacevich as
an independent contractor and whether petitioner is entitled to
section 530 relief. On December 21, 2000, Congress amended
section 7436(a) to provide this Court with jurisdiction to
determine the correct amounts of Federal employment taxes in
worker classification cases. See Community Renewal Tax Relief
Act of 2000 (CRTRA), Pub. L. 106-554, sec. 314(f), 114 Stat.
2763A-643. That amendment was retroactive to August 5, 1997.
CRTRA sec. 314(g), 114 Stat. 2763A-643. On February 8, 2001, the
Court vacated its October 14, 1999, order of dismissal and denied
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011