Juan Ramirez - Page 15

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          respect to the additions to tax under sections 6651(a)(1) and               
          6656 are sustained.                                                         
          IV.  Conclusion                                                             
               We hold that Hernandez, Carlos Ramirez, and Raul Ramirez               
          were employees of petitioner during the periods in issue and that           
          petitioner is not entitled to relief under Revenue Act section              
          530.  Accordingly, petitioner is liable for FICA and FUTA taxes             
          for the periods in issue as determined by respondent.  We also              
          hold that petitioner is liable for the additions to tax                     
          determined by respondent pursuant to sections 6651(a)(1) and                
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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