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HI-Q PERSONNEL, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 22101-04.

132 T.C. No. 13

HI-Q PERSONNEL, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 4, 2009.

Attorney(s) appearing for the Case

Mark E. Cedrone, for petitioner.

Linda P. Azmon, for respondent.

HALPERN, Judge.

The petition in this case was filed in response to a Notice of Determination of Worker Classification (the notice) regarding petitioner's liabilities pursuant to the Federal Insurance Contributions Act (FICA) and for Federal income tax withholding (together, employment taxes) for all taxable quarters in 1995, 1996, 1997, and 1998. After concessions,1 the following questions remain.

(1) Is petitioner collaterally...

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