T.C. Memo. 2007-346
UNITED STATES TAX COURT
JUAN RAMIREZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12139-06. Filed November 26, 2007.
Juan Ramirez, pro se.
Milton B. Blouke and Michael W. Berwind, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: The petition in this case was filed in
response to a Notice of Determination of Worker Classification
regarding petitioner’s liabilities pursuant to the Federal
Insurance Contributions Act (FICA) and the Federal Unemployment
Tax Act (FUTA) for quarterly periods of 2003. After concessions,
the issues for decision are:
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