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ID:
Office:
UILC:
CCA_2010061014441241
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3121.01-01
Number: 201028036
Release Date: 7/16/2010
From: ---
Sent: Thursday, June 10, 2010 2:44:16 PM
To: ---
Cc: ---
Subject: 941X case
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We looked at the materials you sent. There seems to be a conflict in how the ER presents the settlement terms and what they actually were, in terms of ER's knowledge of who got what. On the basis of what we have, I would say the ER remained liable for the ER share of FICA taxes and the fact that it settled with another federal agency for other legal violations for a "total amount" does not eliminate it's liability.
I mentioned to --- that we may want to reach out to the other federal agency b/c I know the TP contacted them as well.
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