§3301 — Rate of tax

3301. "Sec. 7491(a) does not apply to employment tax disputes.

3301, which is in subtit . C . Therefore, sec . 7491(a)(1) is inapplicable .

Attached to the notice are schedules setting forth petitioner’s liabilities for (1) Federal Insurance Contribution Act (FICA) pursuant to sections 3101 and 3111, (2) Federal Unemployment Tax Act (FUTA) taxes pursuant to section 3301, (3) penalties for 2Unless otherwise noted, all section references are to the Internal Revenue Code in effect at all relevant times.

These taxes include those imposed by the Federal Insurance Contributions Act (FICA), §§ 3101– 3128, the Federal Unemployment Tax Act (FUTA), §§ 3301–3311, and income tax withholding under section 3402.

These taxes include those imposed by the Federal Insurance Contributions Act (FICA), §§ 3101–3128, the Federal Unemployment Tax Act (FUTA), §§ 3301–3311, and income tax withholding under section 3402.

§§ 3301–3311, and for federal income tax withholdings, I.R.C. §§ 3401–3406. 3 [*3] Taxable Year FUTA Additions to Tax Ending I.R.C. § 6651(a)(1) I.R.C. § 6651(a)(2) 2010 $805 $181 $201 2011 1,736 391 434 2012 1,260 283 315 2013 1,508 339 377 2014 1,496 337 374 2015 1,532 345 383 Trial of this matter was held on December 13, 2022, during the Court’s

tely 99 individuals listed in the notice of determination and as modified by the Stipulation of Facts3 (nurses)4 are properly classified 2 Unless specifically noted otherwise, the term “federal employment taxes” refers to the taxes imposed under the Federal Insurance Contributions Act (FICA), §§ 3101–3128, the Federal Unemployment Tax Act (FUTA), §§ 3301–3311, and federal income tax withholding, §§ 3401–3406.

3301 (imposing a tax on employers on wages that they pay to their employees). 2(...continued) However, in response to respondent’s statement that they remain unresolved, petitioner stated that she does not seek review of the procedural errors and believes that they are immaterial as respondent has acknowledged that the underlying tax liability

Bell was petitioner’s “employee” for purposes of the Federal Insurance Contributions Act (FICA) under sections 3101, 3102(a), and 3111; the Federal Unemployment Tax Act (FUTA) under section 3301; and income tax withholding under section 3402(a) (together, employment taxes) for the periods listed below.

31.6011(a)-3(a), Employment Tax Regs. 8Employers report (on Form 941) and pay all FICA tax (i.e., the "employee" FICA tax and the "employer" FICA tax) as well as Federal income tax on wage payments on a quarterly basis. See sec. 3402(a); secs. 31.6011(a)-1(a)(1), 31.6011(a)-4(a)(1), Employment Tax Regs.; secs. 31.6011(a)-1T(a)(1), 3

It is a 6.0% tax on the first $7,000 in wages paid to each employee. (continued...) - 7 - claimed to about $170,000--all for unpaid corporate income tax, interest, and penalties. Three months after that, the IRS filed a second amended claim, which wildly increased the debt the IRS said the target owed to more than $3 billion, again all

Section 3301 imposes a tax on every employer with respect to individuals in his employ. For employment taxes related to wages paid before January 1, 2009, a disregarded entity's activities are treated in the same manner as those ofa sole proprietorship, branch, or division ofthe owner. Sec. 301.7701-2(a), Proced. & Admin. Regs. (former regulation),

Section 3301 imposes a tax on every employer with respect to individuals in his employ. For employment taxes related to wages paid before January 1, 2009, a disregarded entity's activities are treated in the same manner as those ofa sole proprietorship, branch, or division ofthe owner. Sec. 301.7701-2(a), Proced. & Admin. Regs. (former regulation),

This is a 6.2% excise tax imposed on each employer with respect to the first $7,000 paid to each employee each year. E sec. 3306(b)(1). The employer must report its FUTA tax liability on a Form 940. Sec. 31.6011(a)-3(a), EmploymentTax Regs. The Form 940 is generally due a month after the end ofthe calendar year. Sec. 31.6071(a)-1(c),

his is a 6.2% excise tax imposed on each employer with respect to wages paid to it employees. Id. Generally, the wages subjectto the tax include "all remuneration or employment" that does not exceed $7,000 for the calendar year. Sec. 3306( )(1). The employer must report its unemployment-tax liability on a Form 940, E ployers' Annual F

Year Quarter 1 Ouarter 2 Ouarter 3 Quarter 4 Total 2005 $3,822.27 $5,617.86 $3,149.51 $4,058.84 $16,648.48 2006 4,193.32 5,588.17 5,776.87 4,163.85 19,722.21 2007 7,540.26 3,439.85 4,717.07 3,795.42 19,492.60 The IRS determined that D&R was liable for the following additions to tax under section 6651(a) (2) : Year Quarter 1 Ouarter 2 Ou

was due. However, it took 10 years before the problem was addressed. In 1998 Congress again amended section 6621 by adding section 6621(d) to authorize interest netting for periods when overpayments and underpayments offset each other. See RRA 1998 sec. 3301, 112 Stat. 741. Section 6621(d) applied prospectively to periods of overlap after July 22, 1998. However, an uncodified special rule in RRA 1998 sec. 3301(c) (2) applied interest netting retroactively. Congress subsequently added to the rul

interest netting and bear the burden of establishing entitlement; and (5) allow a phase-in period of 2 years. See id. at 41-42. Congress rejected most of the recommendations, either in whole or in part, when it enacted section 6621(d). See RRA 1998 sec. 3301. Section 6621(d) provides: SEC. 6621(d). Elimination of Interest on Overlapping Periods of Tax Overpayments and Underpayments. — To the extent that, for any period, interest is payable under subchapter A and allowable under sub-chapter B on

- 63 - Claimed Transferee of Property of BCA Under the Assumption Agreement Respondent argues that petitioner is liable for BCA's tax liability as BCA's transferee because petitioner assumed that liability under the assumption agreement. In support of that argument, respondent asserts: (1) Pursuant to section 2 of the assumption a

d on the wages that we have held are deductible in each of the years at issue. The following rates were in effect with respect to FICA (old-age, survivors, and disability insurance (sec. 3111(a)) and hospital insurance (sec. 3111(b)(6))), and FUTA (sec. 3301) for each of the years at issue: Year FICA FUTA Old Age Hospital 1987 5.7 percent 1.45 percent 6 percent 1988 6.06 percent 1.45 percent 6.2 percent 1989 6.06 percent 1.45 percent 6.2 percent 1990 6.2 percent 1.45 percent 6.2 percent Applying

d on the wages that we have held are deductible in each of the years at issue. The following rates were in effect with respect to FICA (old-age, survivors, and disability insurance (sec. 3111(a)) and hospital insurance (sec. 3111(b)(6))), and FUTA (sec. 3301) for each of the years at issue: Year FICA FUTA Old Age Hospital 1987 5.7 percent 1.45 percent 6 percent 1988 6.06 percent 1.45 percent 6.2 percent 1989 6.06 percent 1.45 percent 6.2 percent 1990 6.2 percent 1.45 percent 6.2 percent Applying

es’ Federal income taxes, secs. 3401 and 3402, (2) the employees’ shares of Federal Insurance Contributions Act (FICA) taxes, sec. 3101, (3) the employer’s share of FICA taxes, sec. 3111, and (4) employer’s Federal Unemployment Tax Act (FUTA) taxes, sec. 3301. Employers are liable for deducting and withholding from their employees’ salaries or wages the employees’ shares of Federal income and FICA taxes. Secs. 162(a), 3102(a), 3402(a), 3403. In general, section 162 allows petitioners’ corporatio

589, 597 (1975); see also Asciutto v.

Section 29 simply provides that the "determination" of "whether any gas is produced from * * * a tight formation shall be made in accordance with [NGPA] section 503".