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After conducting a field examination, the Internal Revenue
Service (IRS) issued to petitioner a Notice of Determination of
Worker Classification (notice of determination), in which it
concluded petitioner erroneously classified its dance instructors
as independent contractors. Petitioner petitioned this Court for
redetermination of the worker classification. After petitioner’s
petition was filed with the Court, respondent forwarded the case
to the IRS Appeals Office. The Appeals officer to whom this case
was assigned conceded the worker classification issue, and a
stipulated decision was entered on the basis of the settlement.
Petitioner filed this motion seeking an award of reasonable
litigation costs. To proceed with petitioner’s motion, the
stipulated decision was vacated and filed as a stipulation of
settled issues. After consideration, we hold that petitioner
shall be awarded litigation costs to the extent determined
herein.
Background
The parties agree that the motion for litigation costs may
be disposed of without a hearing. The stipulation of facts, the
exhibits attached thereto, and the stipulation of settled issues
are incorporated herein by this reference. When petitioner
petitioned this Court, its principal place of business was in El
Paso, Texas.
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Last modified: May 25, 2011