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