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ORION CONTRACTING TRUST v. COMMISSIONER

Docket No. 20633-04.

92 T.C.M. 309 (2006)

T.C. Memo. 2006-211

Orion Contracting Trust, Kevin Peter Carmel, General Manager v. Commissioner.

United States Tax Court.

September 27, 2006.

Attorney(s) appearing for the Case

Kevin Peter Carmel (General Trust Manager), for petitioner.

Denise G. Dengler, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

The petition in this case was filed pursuant to section 7436 and Rule 291 in response to a Notice of Determination of Worker Classification, dated July 28, 2004.1 Respondent determined that, for purposes of Federal employment taxes, petitioner's workers were employees and petitioner owed total employment taxes under subtitle C of the Internal Revenue Code for the years 1996...

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