- 15 -
shown in the 1997 return, additions to tax under sections
6651(a)(2) and 6654 for Ms. Latos’ taxable year 1997, and inter-
est as provided by law. (We shall refer to any such unpaid
assessed amounts with respect to Ms. Latos’ taxable year 1997, as
well as interest as provided by law accrued after June 8, 1998,
as Ms. Latos’ unpaid 1997 liability. We shall refer collectively
to Ms. Latos’ unpaid 1995 liability, Ms. Latos’ unpaid 1996
liability, Ms. Latos’ unpaid 1997 liability, and Ms. Latos’
unpaid 1998 liability as Ms. Latos’ unpaid 1995, 1996, 1997, and
1998 liabilities.)
Respondent issued to Ms. Latos the notice and demand for
payment required by section 6303(a) with respect to Ms. Latos’
unpaid 1997 liability.
On February 9, 2001, respondent received from Ms. Latos a
request for technical advice as to whether Mr. Anderson was an
employee or self-employed during 1996 and 1997. On September 12,
2001, respondent held a telephonic conference with Ms. Latos
regarding respondent’s proposed technical advice with respect to
that request and gave Ms. Latos 21 days within which to respond.
On December 17, 2001, respondent mailed to Ms. Latos the
technical advice memorandum (TAM) that respondent issued in
response to Ms. Latos’ request for technical advice. The effects
of respondent’s conclusions in that TAM were (1) that Mr. Ander-
son was an employee of the owners of the boats on which he
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: November 10, 2007