Central Motorplex, Inc. v. Commissioner

T.C. Memo. 2014-207

UNITED STATES TAX COURT CENTRAL MOTORPLEX, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19754-11. Filed October 7, 2014. William G. Coleman, Jr., for petitioner. William J. Wilkins, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: This case is before the Court on a petition for redetermi- nation of employment status filed pursuant to section 7436.1 In a Notice of Deter- 1 Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1986, as amended and in effect for the taxable year in issue.…