Images in Motion of El Paso, Inc. - Page 5

                                        - 5 -                                         
          petitioner’s arrangement with its instructors strongly evidenced            
          the existence of an employer-employee relationship.                         
          Procedural History                                                          
               On October 2, 2002, respondent issued a 30-day letter to               
          petitioner in which he determined petitioner owed Federal                   
          employment taxes as follows:                                                
                                     Kind of Tax                                      
                       Tax Period     and Code                                        
                         Ended        Section     Amount of Tax                       
                     2000          FUTA, sec.    $2,630.35                            
                                   3301                                               
                     3/31-12/31/00  FICA & FITW1 11,343.96                            
                                   secs. 3101,                                        
                                   3111, 3402                                         
                     2001          FUTA, sec.    6,306.01                             
                                   3301                                               
                     3/31-12/31/01  FICA & FITW  12,890.36                            
                                   secs. 3101,                                        
                                   3111, 3402                                         
                     Total                       33,170.68                            
                    1 Federal income tax withholding.                                 
          Respondent enclosed, with the 30-day letter, IRS Publication 5,             
          Your Appeal Rights And How to Prepare a Protest If You Don’t                
          Agree (Publication 5).  Respondent referred petitioner to                   
          Publication 5 if it intended to request an Appeals Office                   
          conference.                                                                 
               On October 16, 2002, petitioner’s counsel, David P. Leeper             
          (Mr. Leeper), faxed a one-sentence letter requesting an Appeals             
          Office conference.  The examining agent notified Mr. Leeper that            
          petitioner was required to submit a formal written protest.  On             






Page:  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