Orion Contracting Trust, Kevin Peter Carmel, General Manager - Page 4

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          construction work.  During these years, petitioner paid several             
          individuals to assist in its business who provided petitioner               
          with both skilled and unskilled labor.  These individuals                   
          performed work repairing and patching concrete, waterproofing               
          concrete, and other construction work.  Some of the workers                 
          provided their own hammers and Skil-saws.  The rest of the                  
          supplies and materials, including the concrete used by the                  
          workers, were provided by petitioner.                                       
               These individuals were under the direction and control of              
          petitioner, with petitioner’s managers, Carmel and Damigos,                 
          responsible for their management and supervision.  The                      
          individuals worked at more than one location for petitioner                 
          during the years 1996, 1997, and 1998, and petitioner decided               
          which location to send the individuals to.  Many of the                     
          individuals worked for petitioner during all 3 years in question.           
               Petitioner paid these individuals, by cash and check, almost           
          weekly.  Petitioner did not provide any benefits and did not                
          treat any of the individuals as employees for 1996, 1997, or                
          1998.  Petitioner did not file any Forms W-3, Transmittal of Wage           
          and Tax Statements, with accompanying Forms W-2, Wage and Tax               
          Statement, with the Social Security Administration for 1996,                
          1997, or 1998.  Petitioner did not file any Forms 1096, Annual              
          Summary and Transmittal of U.S. Information Returns, with                   
          accompanying Forms 1099, with the Internal Revenue Service (IRS)            






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