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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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