- 15 - 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 6656. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15Last modified: March 27, 2008