Juan Ramirez - Page 2
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(1) Whether Alfredo L. Hernandez, Carlos Ramirez, and
Raul Ramirez were employees of petitioner’s waterproofing
business or independent contractors during 2003;
(2) whether petitioner is entitled to relief under
section 530 of the Revenue Act of 1978, Pub. L. 95-600, 92
Stat. 2885, as amended (Revenue Act section 530);
(3) whether petitioner is subject to the addition to
tax under section 6651 for failing to file Form 940,
Employer’s Annual Federal Unemployment (FUTA) Tax Return,
and Form 941, Employer’s Quarterly Federal Tax Return, for
the periods in issue; and
(4) whether petitioner is subject to the addition to
tax under section 6656 for failing to make deposits of FICA
taxes for the periods in issue.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in California at the time he filed his
petition. For purposes of trial only, this case was consolidated
with a related Federal income tax case at docket No. 12141-06.
From 1999 through 2003, petitioner operated a waterproofing
business as a sole proprietorship called J.R. Waterproofing.
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Last modified: March 27, 2008