- 18 -
workers in question were employees of petitioner and not
independent contractors. Respondent’s determinations with
respect to employment taxes for 1996, 1997, and 1998 are
sustained. Further, because we do not find clear and convincing
evidence of fraud, petitioner is not liable for additions to tax
under section 6651(f).
Accordingly, to reflect the foregoing,
Decision will be entered for
respondent as to the deficiency in
employment taxes and for petitioner
regarding the additions to tax
under section 6651(f).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011