United States Tax Court February 13, 2001, No. 14936-98 (Neely v. Commissioner)

lead-opinion

VASQUEZ, Judge:

Respondent issued to petitioner a notice of determination concerning worker classification. Petitioner contends that respondent is barred from assessing additional employment taxes for the taxable periods in issue on the grounds that the notice of determination was issued after the expiration of the general 3-year period of limitations under section 6501(a).