T.C. Memo. 2004-59
UNITED STATES TAX COURT
BARIUM & CHEMICALS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5668-02. Filed March 10, 2004.
Keith W. Kern, for petitioner.
Linda C. Grobe and William I. Miller, 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 and the Federal Unemployment Tax Act
for 1996, 1997, 1998, and 1999. The issue for decision is
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