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NEELY v. COMMISSIONER

Docket No. 14936-98.

115 T.C. 287 (2000)

U.R. NEELY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 27, 2000.

Attorney(s) appearing for the Case

Kirk A. McCarville, for petitioner.

John W. Duncan, for respondent.

OPINION

VASQUEZ, Judge:

Respondent issued to petitioner a notice of determination concerning worker classification. Petitioner contends that such determination was time barred under section 6501(a).1 Respondent contends that the period of limitations on assessment remains open, pursuant to section 6501(c), on account of petitioners' fraudulent conduct. The Court, sua sponte, questioned...

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