Synergy Staffing, Inc. v. United States
Opinion
Opinion
Stotler, J.
STATEMENT OF UNCONTROVERT-ED FACTS AND CONCLUSIONS OF LAW
STATEMENT OF UNCONTROVERTED FACTS
1. Plaintiff is a corporation doing business within the Central Judicial District of California. (Complaint and Answer, ¶ 1.)
2. The instant action is for a refund of federal payroll taxes for the four quarterly periods in 1997. (Complaint.)
3. On June 4, and June 26, 1997, the Internal Revenue Service assessed Form 941 payroll tax liabilities against Personnel Connection, Inc., for the first quarter of 1997. (Request for Judicial Notice, Attachment 1, pp. 1 and 2.)
4. On July 29, 1997, the Internal Revenue Service assessed a Form 941 payroll tax liability against Personnel Connection, Inc., for the second quarter of 1997. (Request for Judicial Notice, Attachment 2, p. 1.)
5. On November 14,1997, and April 13, 1998, the Internal Revenue Service assessed Form 941 payroll tax liabilities against Personnel Connection, Inc., for the third quarter of 1997. (Request for Judicial Notice, Attachment 3, pp. 1 and 3.)
6. On March 16, 1998, the Internal Revenue Service assessed a Form 941 payroll tax liability against Personnel Connection, Inc., for the fourth quarter of 1997. (Request for…