T.C. Memo. 2007-66 UNITED STATES TAX COURT PENO TRUCKING, INCORPORATED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21070-03. Filed March 21, 2007. Brent L. English, for petitioner. Linda C. Grobe, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge: The petition in this case was filed in response to a Notice of Determination Concerning Worker Classification Under Section 7436 regarding petitioner’s liabilities pursuant to the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA) for 1997,Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007