Colorado Mufflers Unlimited, Inc. - Page 1

                                 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.                                                              

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Last modified: November 10, 2007