(Request for Judicial Notice, Attachment 5.)ĩ. SA CV 00-321-AHS, seeking a refund of federal payroll taxes paid by plaintiff for various tax periods, including the first, second, and third quarters of 1997. On April 3, 2000, plaintiff Synergy Staffing, Inc., fka Personnel Connection, Inc., filed a lawsuit in this Court, case no. (Complaint and Answer, ¶ 5 Declaration of Thomas Tang, Exhibits A through H and Request for Judicial Notice, Attachments 1, 2, 3, and 4.)Ĩ. The payroll tax assessments against the plaintiff for each of the four quarterly periods in 1997 were made by the IRS pursuant to payroll tax returns and monthly payroll tax reports submitted to the IRS by the taxpayer.

(Request for Judicial Notice, Attachment 4, p. 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 Judicial Notice, Attachment 3, pp. 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 2, p. 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 1, pp. 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. The instant action is for a refund of federal payroll taxes for the four quarterly periods in 1997. Plaintiff is a corporation doing business within the Central Judicial District of California. STATEMENT OF UNCONTROVERTED FACTS AND CONCLUSIONS OF LAWġ. Robbins, Jr., Assistant United States Attorney, Chief, Tax Division, Darwin Thomas (SBN 80745), Assistant United States Attorney, Los Angeles, CA, for United States of America. UNITED STATES of America (Internal Revenue Service) and Does 1 through 10, inclusive, Defendants. SYNERGY STAFFING, INC., fka Personnel Connection Inc., Plaintiff,

Synergy staffing