David E. Watson, Pc v. United States

ORDER ON BENCH TRIAL

ROBERT W. PRATT, Chief Judge.

On or about February 5, 2007, the United States of America (“Defendant” or “Government”) recharacterized dividend and loan payments from David E. Watson, P.C. (“DEWPC” or “Plaintiff’) to its sole shareholder and employee, David E. Watson (“Watson”), as wages. Compl. (Clerk’s No. 1) ¶ 10. In light of this recharacterization, Defendant assessed additional employment taxes, interest and penalties against Plaintiff for each of the eight calendar quarters in 2002 and 2003. Id. DEWPC paid the fourth quarter 2002 assessment of $4,063.93 on or about…