Henry Randolph Consulting v. Commissioner
United States Tax Court
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
OPINION
Cohen, Chief Judge:
In Henry Randolph Consulting v. Commissioner, 112 T.C. 1 (1999) (Randolph Consulting I), we considered and granted respondent’s motion to dismiss for lack of jurisdiction and to strike as to the amounts of employment taxes proposed for assessment by respondent for the years in issue. The case is now before the Court on petitioner’s motion for judgment on the pleadings, which is more properly characterized as petitioner’s motion to dismiss for lack of jurisdiction, on the ground that respondent did not issue a valid notice of determination concerning worker…
2Cases cited9 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Scar v. CommissionerUnited States Tax Court · 1983
- Clapp v. CommissionerCourt of Appeals for the Ninth Circuit · 1989
- Campbell v. CommissionerUnited States Tax Court · 1988
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003
- Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003
- Charlotte's Office Boutique, Inc. v. CommissionerUnited States Tax Court · 2003
- Henry Randolph Consulting v. CommissionerUnited States Tax Court · 1999
- Henry Randolph Consulting v. CommissionerUnited States Tax Court · 1999