Legal Opinion

Henry Randolph Consulting v. Commissioner

United States Tax Court

Decided October 19, 1999No. 6838-98Published

P has moved to dismiss this case for lack of jurisdiction on the ground that the Notice of Determination Concerning Worker Classification Under Section 7436 is invalid for failure to identify by name the individuals determined by respondent to be employees. HELD: The notice is not invalid, and P's motion is denied.

1Opinion of the Court

HENRY RANDOLPH CONSULTING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Henry Randolph Consulting v. Commissioner

No. 6838-98

United States Tax Court

113 T.C. 250; 1999 U.S. Tax Ct. LEXIS 48; 113 T.C. No. 20;

October 19, 1999, Filed

An order denying petitioner's motion will be issued.

P has moved to dismiss this case for lack of jurisdiction

on the ground that the Notice of Determination Concerning Worker

Classification Under Section 7436 is invalid for failure to

identify by name the individuals determined by respondent to be

employees. HELD: The notice is not invalid, and P's motion is

den…

2Cases cited10 opinions

  1. Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  2. Mayerson v. CommissionerUnited States Tax Court · 1966
  3. Scar v. CommissionerUnited States Tax Court · 1983
  4. Clapp v. CommissionerCourt of Appeals for the Ninth Circuit · 1989
  5. Campbell v. CommissionerUnited States Tax Court · 1988

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