HALPERN, Judge:
Respondent's Appeals Office (Appeals) has determined to proceed with the collection from petitioner of Federal Unemployment Tax Act (FUTA) tax, a penalty, an addition to tax, and interest for 1996. The crux of the parties' disagreement is whether, for 1996, petitioner paid $17,553 to the State of California.
Unless otherwise stated, all section references are to the Internal Revenue Code in effect for 1996, and all Rule references
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