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PENO TRUCKING, INCORPORATED v. COMMISSIONER

Dkt. No. 21070-03.

93 T.C.M. 1027 (2007)

T.C. Memo. 2007-66

Peno Trucking, Incorporated v. Commissioner.

United States Tax Court.

March 21, 2007.

Attorney(s) appearing for the Case

Brent L. English, for petitioner.

Linda C. Grobe, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

The petition in this case was filed in response to a Notice of Determination Concerning Worker Classification Under Section 7436 regarding petitioner's liabilities pursuant to the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA) for 1997, 1998, and 1999 and each of the quarters therein (periods at issue).1

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