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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