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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
6656.
To reflect the foregoing,
Decision will be entered
for respondent.
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