T.C. Memo. 2007-222 UNITED STATES TAX COURT COLORADO MUFFLERS UNLIMITED, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4083-04. Filed August 13, 2007. Dolores Rudd (an officer), for petitioner. David A. Conrad and Milan Kim, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: In a Notice of Determination of Worker Classification (notice of determination) under section 7436,1 respondent determined that nine workers were employees of 1Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the periods in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007