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IMAGES IN MOTION OF EL PASO, INC. v. COMMISSIONER

Dkt. No. 7663-03.

91 T.C.M. 716 (2006)

T.C. Memo. 2006-19

Images in Motion of El Paso, Inc. v. Commissioner.

United States Tax Court.

February 7, 2006.

Attorney(s) appearing for the Case

David P. Leeper, for petitioner.

Michael K. Park, for respondent.

MEMORANDUM OPINION

GOEKE, Judge.

This matter is before the Court on petitioner's motion for award of reasonable litigation costs under section 7430 and Rule 231.1

After conducting a field examination, the Internal Revenue Service (IRS) issued to petitioner a Notice of Determination of Worker Classification (notice of determination), in which it concluded petitioner erroneously classified its dance instructors as independent...

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