Legal Opinion

SECC Corp. v. Commissioner

United States Tax Court

Decided April 3, 2014No. Docket No. 3937-12Published

In this case brought under I.R.C. sec. 7436, P seeks our determination of the proper classification of P's workers for employment tax purposes and certain related issues. R sent P a letter (April 15, 2011, letter) which stated that P's employment tax liabilities as determined by Appeals will be assessed. The letter was not sent by certified or registered mail. P petitioned this Court more than 90 days after R sent the April 15, 2011, letter.

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In this case brought under I.R.C. sec. 7436, P seeks our determination of the proper classification of P's workers for employment tax purposes and certain related issues. R sent P a letter (April 15, 2011, letter) which stated that P's employment tax liabilities as determined by Appeals will be assessed. The letter was not sent by certified or registered mail. P petitioned this Court more than 90 days after R sent the April 15, 2011, letter. Held: The April 15, 2011, letter was a determination relating to the classification of P's workers for employment tax purposes. Held, further, the…

1Opinion of the Court

SECC CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

SECC Corp. v. Comm'r

Docket No. 3937-12.

United States Tax Court

142 T.C. 225; 2014 U.S. Tax Ct. LEXIS 12; 142 T.C. No. 12;

April 3, 2014, Filed

In this case brought under I.R.C. sec. 7436, P seeks our determination of the proper classification of P's workers for employment tax purposes and certain related issues. R sent P a letter (April 15, 2011, letter) which stated that P's employment tax liabilities as determined by Appeals will be assessed. The letter was not sent by certified or registered mail. P petitioned this…

Also in this document: Concurrence.

2Cases cited22 opinions

  1. Adams Fruit Co. v. BarrettSupreme Court of the United States · 1990
  2. United States v. WoodsSupreme Court of the United States · 2013
  3. Craig v. Comm'rUnited States Tax Court · 2002
  4. Fox Television Stations, Inc. v. Federal Communications Commission and United States of America, National Association of Broadcasters, IntervenorsCourt of Appeals for the D.C. Circuit · 2002
  5. Breman v. CommissionerUnited States Tax Court · 1976

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