- 3 -
Taxable period ended 2000
Tax/addition/penalty Mar. 31 June 30 Sept. 301 Dec. 31 Total
FICA $6,200.18 $6,200.18 $6,200.18 $6,200.18 $24,800.72
Income tax 11,346.72 11,346.72 11,346.72 11,346.72 45,386.88
Sec. 6651(a)(1) --- --- 4,386.73 4,386.73 8,773.46
Sec. 6662 3,509.28 3,509.28 --- --- 7,018.56
FUTA --- --- --- 3,337.83 3,337.83
Sec. 6651(a)(1) --- --- --- 843.33 843.33
Total 21,056.18 21,056.18 21,056.18 26,114.79 90,160.78
1The entries in the designated column do not add up to the total shown
for the column. Respondent will have to clarify the extent of his concession
in a Rule 155 computation.
Taxable period ended 2001
Tax/addition/penalty Mar. 31 June 30 Sept. 30 Dec. 311 Total1
FICA $6,200.17 $6,200.17 $6,200.17 $6,200.17 2$24,800.88
Income tax 11,346.72 11,346.72 11,346.72 11,346.72 45,386.88
Sec. 6651(a)(1) 4,386.73 4,386.73 4,386.73 4,386.73 17,546.92
FUTA --- --- --- 3,337.83 3,337.83
Sec. 6651(a)(1) --- --- --- 843.33 843.33
Total 21,933.62 21,933.62 21,933.62 26,958.11 92,758.97
1The entries in the designated columns do not add up to the total shown
for the column. Respondent will have to clarify the extent of his concession
in a Rule 155 computation.
2The entries in this row do not add up to the total shown for the row.
Respondent will have to clarify the extent of his concession in a Rule 155
computation.
After concessions,2 the issues for decision are:
(1) Whether Richard D. Rudd, Sr., Richard D. Rudd, Jr.,
Sherilyn J. Gallegos, George Gallegos III, Sean L. Turner, Gary
W. Neilson, Shanna Rudd, Brian Welling, and Michael L. Steward
(hereinafter the workers) were employees of petitioner during
2000 and 2001; and
2Petitioner does not directly address respondent’s revised
adjustments regarding the sec. 6662 accuracy-related penalty or
the additions to tax under sec. 6651(a) in its briefs.
Therefore, we will deem petitioner to have conceded these
adjustments if we conclude that respondent’s determination
regarding the classification of the workers is sustained. See
Rule 151(e)(4) and (5); Petzoldt v. Commissioner, 92 T.C. 661,
683 (1989).
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Last modified: November 10, 2007