2017-46 Closing Agreement with IRSRESOLUTION NO. 2017-46
A RESOLUTION OF THE VILLAGE COUNCIL OF THE VILLAGE OF
NORTH PALM BEACH, FLORIDA, APPROVING A CLOSING AGREEMENT
WITH THE INTERNAL REVENUE SERVICE REGARDING WORKER
CLASSIFICATION AND AUTHORIZING THE VILLAGE MANAGER TO
EXECUTE THE CLOSING AGREEMENT AND AN ASSESSMENT AGREEMENT
FOR ADDITIONAL TAXES; AND PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, the Internal Revenue Service ("IRS") conducted an audit for the 2015 tax year and
determined that additional taxes were owed for certain employees and/or fringe benefits in the
total amount of $9,947.48; and
WHEREAS, the IRS further determined that certain recreation and golf instructors were
improperly classified as independent contractors and the Village has agreed to execute a
Closing Agreement and pay the sum of $11,592.72 in additional taxes as full settlement of this
matter for the 2015, 2016 and a portion of the 2017 (through September 30, 2017) tax years; and
WHEREAS, the Village Council determines that the execution of a Closing Agreement is in the
best interests of the residents and citizens of the Village of North Palm Beach.
NOW, THEREFORE, BE IT RESOLVED BY THE VILLAGE COUNCIL OF THE VILLAGE
OF NORTH PALM BEACH, FLORIDA, as follows:
Section 1. The foregoing recitals are ratified and incorporated herein.
Section 2. The Village Council hereby approves a Closing Agreement on Final Determination
Covering Specific Matters Regarding Worker Classification with the Internal Revenue Service in
the amount of $11,592.72 and authorizes the Village Manager to execute the Agreement on
behalf of the Village. The Village Council further authorizes the Village Manager to execute an
Assessment Agreement relating to the payment of additional taxes for employees and/or fringe
benefits in the amount of $9,947.48. Funds for this expenditure shall be allocated as follows:
$10,406.72 from Account No. L8070-33115 (Country Club — Legal Settlement) and $11,133.48
from Account No. A5540-33115 (General Fund — Legal Settlement).
Section 3. This Resolution shall be effective immediately upon adoption.
PASSED AND ADOPTED THIS 22' DAY OF JUNE, 2017.
(Village Seal)
ATTEST:
VILLAGE CLERK
4�46� �o Ott
L7��
MAYOR
Internal Revenue Service Department of the Treasury
Tax Exempt and Government Entities Division
Federal, State and Local Governments
1700 Palm Beach Lakes Boulevard
Stop 7250
West Palm Beach, FL 33401
Date: 5-26-2017
Taxpayer Identification Number:
Village of North Palm Beach 59-6017984
Attn: Erica Ramirez Form Number:
501 US Highway 1 941
North Palm Beach, FL 33408 Tax Period(s) Ended:
12-31-2015
Person to ContactIlD Number:
Michael Moore
1000875879
Contact Telephone Number:
561-616-2092
Contact Fax Number:
855-243-4016
Refer Reply To:
Stop 7250
Last Date to Respond to this Letter:
6-26-2017
Dear Erica Ramirez,
We are proposing changes to your employment tax for the tax periods indicated above. Please tell
us whether you agree or disagree with the proposed changes by the date shown above. This letter
(known as a 30-day letter) notifies you of your rights to appeal the proposed changes within 30
days.
We have enclosed Form 4666, Summary of Employment Tax Examination, Form 4667,
Examination Changes -Federal Unemployment Tax, and/or Form 4668, Employment Tax
Examination Changes Report. These documents provide details on how we calculated the
proposed amount of your additional employment tax liability. Please note that these amounts do not
include any interest that may apply. If we propose any adjustments for employment tax that involve
a worker classification determination, we will send you a separate letter, Letter 950-C, Employment
Tax 30-Day Letter-WC.
If you agree with the proposed changes
1. Sign and date the enclosed agreement form(s), Form 2504, Agreement to Assessment and
Collection of Additional Tax and Acceptance of Overassessment and/or Form 2504-S,
Agreement to Assessment and Collection of Additional Tax and Acceptance of Overassessment
(including section 530 statement). Sending us a signed Form 2504/Form 2504-S gives us
permission to assess the proposed amounts. Signing Form 2504/Form 2504-5 will not prevent
you from filing a claim for refund if you later believe you are entitled to a refund. It will not
Letter 950- D (Rev. 11.2010)
Catalog Number 48702P
2
prevent us from later determining, if necessary, that you owe additional tax; nor extend the time
provided by law for either action.
2. Return the signed Form 2504/Form 2504-S to us.
3. Enclose payment for the employment tax and additions to tax and penalties due. Make your
check or money order payable to the United States Treasury. We will bill you for applicable
interest, if any. If you pay now, you will limit the amount of any interest, additions to tax, and
penalties charged to your account. If you agree with the proposed changes but cannot pay the
full amount, we will bill you for the unpaid amount.
You may qualify for interest-free treatment if the amounts underreported do not relate to an issue
that was raised in an examination of a prior period and if you did not knowingly underreport your
employment tax liability. In order for the adjustment to be entirely interest-free, you must pay the
amount due when you submit the signed Form 2504/Form 2504-S. Otherwise, interest will accrue
from the date you submit the signed Form 2504/Form 2504-S. Even if payment is not made until
after receipt of notice and demand, you are nevertheless entitled to interest-free treatment up to the
date you submit the signed Form 2504/Form 2504-S; however, interest will accrue from the date
the signed Form 2504/Form 2504-S is submitted until the date of payment.
Please refer to Publication 3498, The Examination Process, for payment options. If you are a
debtor in a bankruptcy case, payment should only be made in accordance with the Bankruptcy
Code.
If you do not agree with the proposed changes
1. You may request a meeting or telephone conference with the supervisor of the IRS contact
person identified on the front page of this letter. If you still do not agree after the meeting or
telephone conference, you can:
2. Request a conference with our Appeals Office. If you want to have a conference with an appeals
officer, you will need to submit either a small case request or a formal written protest with the
IRS contact person named in this letter. Based on the total changes to your employment tax
liability for each referenced tax return for the tax periods indicated, we have indicated whether
you need to submit either a small case request or a formal written protest. Note: If we've
proposed any adjustments for employment tax for a referenced tax return and tax period that
involve a worker classification determination (as reflected in a separate letter), we've included
those proposed adjustments in tax (including additions to tax and penalties) in computing the
total amount. See the box checked below:
® Small case request. If you want to have a conference with an appeals officer, you can submit
a small case request. Since the total amount of the proposed changes to your tax, additions to tax,
and penalties is $25,000 or less for each referenced tax return for a tax period, you can send us a
letter requesting consideration by Appeals. Indicate the issues you do not agree with and the
reasons why you do not agree. If you do not want to write a separate letter, you can complete the
enclosed Form 13683, Statement of Disputed Issues, and return it to us.
❑ Formal protest. If you want to have a conference with an appeals officer, you must submit a
formal written protest. Since the total amount of the proposed changes to your tax, additions to tax,
Letter 950-D (Rev. 11-2010)
Catalog Number 48702P
3
and penalties is more than $25,000 for any referenced tax return for a tax period, you must submit
a formal protest. Note: If more than one tax period is involved and any tax period exceeds the
$25,000 threshold, you must submit a formal written protest for all periods involved. Form 13683
cannot be used to make a formal protest.
If you request a conference with our Appeals Office, an appeals officer will call you (if necessary)
for an appointment to take a fresh look at your case. The Appeals Office is an independent office
and most disputes considered by the Appeals Office are resolved informally and promptly. By
requesting a conference with our Appeals Office you may resolve the matter sooner.
The requirements for filing a formal protest are explained in the enclosed Publication 3498. The
publication also includes information on the Declaration of Taxpayer Rights and the IRS Collection
Process. References to 90-Day letters and to the United States Tax Court in Publication 3498 do
not apply to this case. The United States Tax Court does not have jurisdiction to review this
employment tax case because it does not involve worker classification issues.
What happens if you do not reach an agreement with our Appeals Office or if you do not
respond to this letter?
If you do not reach an agreement with our Appeals Office or if you do not respond to this letter, we
will assess the employment tax and any applicable interest, additions to tax, and penalties, and
notify you of the balance due.
You may seek judicial review of the assessment by filing a refund suit in district court or in the
United States Court of Federal Claims. Please note that before a refund suit can be filed, you must
pay to the IRS the amount of employment tax that relates to one worker for one tax period and file
a claim for refund with the IRS. If the claim for refund is denied (or the IRS does not respond to the
refund claim within six months), you may file a refund suit in district court or the United States Court
of Federal Claims and challenge the employment tax assessment.
If you have any questions about this letter, you may write to the IRS contact person whose name is
shown on the front page of this letter. If you write, please include your daytime telephone number,
the best time for us to call you if we need more information, and a copy of this letter to help us
identify your account. Keep the original letter for your records.
If you prefer, you may call the IRS contact person at the telephone number on the front page of this
letter. If this number is outside your local calling area, there will be a long distance charge to you.
You may call the Business and Specialty Tax Line 1-800-829-4933 or you may call or visit your
local IRS office to obtain general information. An IRS employee there may be able to help you, but
the IRS contact person at the telephone number on the front page of this letter is most familiar with
your case.
You also have the right to contact a Taxpayer Advocate. The Taxpayer Advocate Service (TAS) is
an independent organization within the IRS whose employees assist taxpayers who are
experiencing economic harm, who are seeking help in resolving tax problems that have not been
resolved through normal channels, or who believe that an IRS system or procedure is not working
as it should. If you believe you are eligible for TAS assistance, you can reach them by calling the
Letter 950-D (Rev. 11.2010)
Catalog Number 48702P
4
TAS toll-free case intake line at 1-877-777-4778 or TTY/TDD 1-800-829-4059. For more
information, go to www.irs.govladvocate.
If we propose any adjustments for employment tax that involve worker classification issues, you will
receive a separate letter.
MAIL ALL RESPONSES TO:
Internal Revenue Service
1700 Palm Beach Lakes Blvd.
Vilest Palm Beach, FL 33401
An envelope is enclosed for your convenience.
Thank you for your cooperation.
Sincerely yours,
Michael Moore
Federal, State and Local Governments
Enclosures:
Copy of this letter
Examination Report
® Form 2504
❑ Form 2504-S
® Form 4666
❑ Form 4667
® Form 4668
® Form 13683
Publication.3� PW
Envelope
Letter 950-D (Rev. 11-2010)
Catalog Number 48702P
Date Received by
Form 2504 Department of the Treasury-Internal Revenue Service Internal Revenue
Service
(February 2014) Agreement to Assessment and Collection of Additional Tax and Acceptance
of Overassessment
(Excise or Employment Tax)
Taxpayer(s)name D/B/A SSNIEIN
Village of North Palm Beach 59-6017984
Address of taxpayer(s)(number,street) City/Town State ZIP code
501 US Highway 1 North Palm Beach IFL 33408
A�ustment to Tax, Credits and Penalties
Tax Period Ended Return Form Kind of Tax and Internal Amount of Tax Credit Increase (Decrease) Penalty
number Revenue Code Section
Total 9,947.48 0.00 0.00
/consent tothe immediate assessment(Increase intax and penalties endhdecrease in credits)and the collection ofany such amounts. |naddition. |
accept any ovenaaoeuament(decrease in tax mndpanwltieoandlh/inomaaaincredits)shown above. |also agree toany interest omprovided bylaw.
Sign Date:
Here
Sign Date:
Here
Sign JTItIe: Date:
Here '-Z/
If you consent to the assessment of the amounts shown in this agreement,your signature will expedite Our adjustment to your account. Your consent will
not prevent you from filing aclaim for refund(after you have paid the tax)ifyou later believe you are entitled|oarefund. |twill not prevent uefrom later
determining, if necessary,that you owe additional tax; nor extend the time provided by law for either action,
Who Must Sign
|fyou are making this agreement for opartnership, all partners must sign, However,one partner may sign with appropriate evidence o[authorization ho
act for the partnership.
For a corporation,enter the officer or officers of the corporation followed by the signature and title of the officer(s)authorized to sign,
For an agent or attorney acting under a Power of Attorney authorization must attach the authorization to this form unless it is already filed with us.
Memo: Abatement amount under IRC 34U2(d)and/or IRC 31O2(f)(3)-See explanation onForm 48GG
Return Form Return Form
Tax Period Ended Number IRC Code Credit for Abatement Tax Period Ended Number IRC Code Credit for Abatement
Form 2504(Rev.u'uo11) Catalog Number u1rrox publish.no.im.nov oepmnmontmmetmaaury-|nmma|wovnnuamemice
Form 4666 Department of the Treasury-Internal Revenue Service
(R. Mad,20115 Summary of Emplo ment Tax Examination
Name and Address of Employer Employer identification Number Dale of Report
Village of North Palm Beach 59.8017984 5/22/2017
501 US Highway 1 Type of Report
North Palm Beach FL 33408 Delingaant rax Increase(Decrease)in Tax
Ratum riot fried x Return filed
X Agreed m+i. p.M..M d m rmlar.W y—A b b%d by
0a Diedar when M N accepbtll
Una reed
Following is a summary of the results of my examination of your returns as shown on the attached pages of this report.
Tax Credits and penalties
a b c d a f
Calendar Year Return Form Delinquent Tax,increase Increase(Decrease)in Penalty Total Adjustment and Penalties Page number
Number (Decrease)in Tax Allowed Credits Code Section Amount (a+d+e) of Report
2015 941 9,947.48 - 9,947.48
Total I $9,947.48 $0.00 9,947.48
Other Information
The examination of your employment tax returns as reflected on this Agreement included an examination for employment tax purposes of whether golf, tennis,
dance,pool,fitness and karate instructors,a medical director and entertainers should be treated as employees of the taxpayer. Section 530 of the Revenue Act
of 1978 as amended by Section 1122 of the Small Business Job Protection Act of 1996 provides that taxpayers may rely on a prior audit commenced after
December 31, 1996,when the audit included an examination for employment tax purposes of whether the individual involved(or any individual holding a position
substantially similar to the position held by the individual involved)should be treated as an employee of the taxpayer. Based upon this exalmination,yuu maY rely
only on the audit of medical director and entertainers that did not result in a reclassification for purposes of the prior audit safe haven for satisfying the reasonebie
basis.Cyuirclt"el't of Section 53U.
This dices cilli G0115litUte aai 111C.Onie lax ekeipt.1 latio 1.
rllnit 2bU4 Gori illi.tieciiu i 1436 i�$1,eti
Ei:,fi.:Gd:,J!Fi_ctu�Qr.vti4 ui,^.tu^a'y7 C%!'r:r.'i iJC VEJ
M 1,!10-. ....ir..,. �}) •M1M1�O�i Off, �if`� f`1C nM1M1h
Calo..y, ,,tee,,, r {•��// (( .1v....�._.._„_�...® u.,,4tti6 ,tc.-u3[u 1}
Page of 3 Pages
Form 4668 Department of the Treasury-Internal Revenue Service Return Form number
(APril2014) Employment Tax Examination Changes Report 941
Name of Employer Employer Identification number Calendar year
Village of North Palm Beach 59-6017984 2015
Address of Employer Total tax plus penalty,or(decrease)in tax
801 US Highway 1 Last quarter of this
North Palm Beach $ 9,947.48 examination
FL 3344$ Total increase or(decrease)in credits December,2015
Examination discussed with(Name and title) x Agreed(Subject to acceptance of the Director)
Andy Likasik,Village Manager
Unagreed
(b) (c) ( e
1st 2nd 3rd 4th
Quarter Quarter Quarter Quarter
1 . Total Social security and Medicare tax adjustment(from
Schedule of Adjustments,Line 14) 1,748.29 1,748.29 1,748.29 1,748.29
2. Social security and Medicare wage adjustment under IRC
3121(q)(from Schedule of Adjustments,Line 11)
3 Increase(decrease)in tax exemption on exempt wages/tips
(From Schedule of Adjustments,Line 13)
Total Income tax withholding(from Schedule of
4 Adjustments,Line 20) 738.58 738.58 738,58 738.58
Delinquent tax or increase(decrease)in tax(Lines 1,2 and
5. 4 minus/plus Line 3) 2,486.87 2,486.87 2,486.87 2,486.87
Net increase(decrease)in credits(from Schedule of
6 Adjustments,Line 26)
-----
7. Penalty code section 6651(a)(1)
8 Penalty code section 6651(a)(2)
9. Penalty code section 6656
10. Penalty code section
11 . Total penalty(sum Lines 7,8,9 and 10) $ $ $ $
12. Maximum tax available for abatement under IRC 3402(d) $ 738.58 $ 738.58 $ 738.58 $ 738.58
13, Maximum tax available for abatement under IRC 3102(f)(3) $ - $ - $ $
Furnish Form W-2(Wage and Tax Statement)or Form W-2c(Corrected Wage and Tax Statement)on or before January 31,2018 to each of the one employees
whose wages are adjusted by this report.
File Forms W-2 with Form W-3(Transmittal of Wage and Tax Statements)or Forms W-2o with Form W-3c(Transmittal of Corrected Wage and Tax Statements)
on or before January 31,2018 with the Social Security Administration(SSA).
IRC 6721 and 6722 provide penalties for failure to file and failure to furnish information returns. You must file the information returns electronically if you are
required to file 250 or more returns. To obtain specifications for e-filing your returns,visit the SSA's website at www.socialsecur4.gov/employer. If filing paper
returns,file with the SSA at the appropriate address in the General Instructions for Forms W-2 and W-3(Including Forms W-2AS,W-2CM,W-2GU,W-2VI,W-
3SS,W-2c,and W-3c).
LISPS to: Other Courier Service to:
Social Security Administration Social Security Administration
Direct Operations Center Direct Operations Center
Wilkes-Barre, PA 18769-0001 Attn: W-2c Process
1150 E. Mountain Drive
Wilkes-Barre, PA 18702-7997
Form 2504 non-section 7436 issues
Examiner's signature Examiner's ID# Group Number Area Date
Michael Moore "
1000875879 7252 Gulf Coast May 22,2017
Catalog Number 232752 www.irs.gov Form 4668(Rev.4-2014)
Page o2- of__L Pages
i,
Schedule of Adjustments
Name of Employer Employer Identification number Calendar year
Village of North Palm Beach 59-6017984 2015
Adjustment to FICA Wages and Tax
(a) (b) (c) (d) (e)
Applicable 1st 2nd 3rd 4th
IRS Ref. Rate Quarter Quarter Quarter Quarter
1 Social security and Medicare wage adjustment subject to 004 12.4% 11,428.75 11,426 75 11,426-75 11,426.75
tax under IRC 3101 and 3111
073 2.90% 11,426 75 11,42675 11.426 75 11,426 75
2 Social security and Medicare wage adjustment subject to 7"%
tax under IRC 3509(a) 079
1.74% - - - -
3 Social security and Medicare wage adjustment subject to
8--a ggo�
tax under IRC 3509(b) 079
4 Social security and Medicare tip adjustment subject to 005 6,20%
tax under PC 3101 and 3111
073 1.46°IQ
5 Additional Medicare wage andlor lip adjustment subject
to tax under IRC 3101(b)(2) 074 0.90°
6 Additional Medicare wage and/or tip adjustment subject _
to tax under IRC 3101(b)(2)and 3509(a) 079 0.18°1
7 Additional Medicare wage andlor tip adjustment subject I i
to tax under IRC 3101(b)(2)and 3509(b) 079 0.36% II I
8 Otheras dust;nests to Sociat Security and Medicare i
9
9 Other adpuents to Social Security and Medicare
efinS
rn Total social security and Medicare tax
# 1 throkiah 8.-,ern ^r:sin•„n.ls F-y 9' 112 t i ?4°_. C -: t 1-4 ? 1?4`..
I i
1 Social Security and Medicare tax”adju°stmerlt under i
312iiu, I, Std
Increase(decrease)in exempt wa(t{`JMPS paid t0
gt;ajiliFri em Dipyilo.;krnn�r IRC,
i t '
i
i3 Increase trlPrreii5e}In tfl%P%P,mnrkf)n nn+.vBr�P,S�tl r)S en _� I
I i I
i-ino I22 i L ilia E21:t rat2t
i✓Ntdtvy iv iiill'uei 732 r75Z L.........Cj6v. Fc,rm 4c G. I, ev.u-1-E014)
Page 3 of 3 Pages
Schedule of Adjustments Continued
Name of Employer Employer Ident taoaison number Calendar year
Village of North Palm Beach 59-6017984 2015
Adjustment to Wages and Tax for Income Tax Withholding
(a) (b) (c) (d) (e)
Applicable 1st 2nd 3rd 4th
IRS Ret. Rate Quarter Quarter Quarter Quarter
14 Income withholding wage adjustment subject to tax under
section 3402 6.46% 11,426.75 11,426.75 11,42675 11,426.75
15 Income tax withholding wage adjustment subject to rates
under IRC 3509(a) 079 1.50% - - -
16. Income tax withholding wage adjustment subject to rates
under IRC 3509(b) 079 3.00%
17. Other income tax withholding wage adjustment
18 Actual income tax withheld but not previously reported
19, Other adjustment to income withholding
20, Total income tax(Lines 14,15,16,17 x rates plus Line
18 plustminus Line 19) 111 $ 738.58 $ 738,58 $ 738.58 $ 738.58
Adjustment to Credits Against the Tax
21 Increase(decrease)in COBRA premium assistance
payments under IRC 6432 229
22 Increase(decrease)in Advance Earned Income Credit
under IRC 3507 7661767
Increase(decrease)in exempt wagesttips paid to
23. qualified employees March 19-31,2010 under IRC 117
3111(d)(5)
24 Increase(decrease)in credit for exempt wages/tips on
Line 23(Line 23 x rate) 296
25. Increase(decrease)in other credits
Net increase(decrease)in credits(sum of Lines 21,22,
26. 24 and 25) $ $ $ $
Catalog Number 23275Z www.irs.gov Form 4668(Rev.04-2014)
Internal Revenue Service Department of the Treasury
Date:
5-26-2017
Taxpayer Identification Number:
Village of Palm Beach 59-6017984
Form:
501 US Highway 1 941
Norht Palm Beach, FL 33408 Tax Period(s)Ended:
12-31-2015
Person to Contact:
Michael Moore
Contact Telephone Number:
561-616-2092
Contact Fax Number:
855-243-4016
Employee Identification Number:
1000875879
Refer Reply to:
Stop 7250
Last Date to Respond to this Letter:
Dear Erica Ramirez, 6-26-2017
We are proposing changes to your employment tax based on a proposed worker classification determination for
the tax periods indicated above. Please tell us whether you agree or disagree with the proposed changes by the
date shown above. This letter(known as a 30-day letter) notifies you of your rights to appeal the proposed
changes within 30 days.
We propose to make three determinations:
1. WORKER CLASSIFICATION. For purposes of federal employment taxes, the individual(s) listed or
described in the attachment to this letter are to be legally classified as employees for the tax periods
indicated;
2. SECTION 530 TREATMENT. With respect to such individual(s), you are not entitled to relief from
employment tax under the treatment described in section 530(a) of the Revenue Act of 1978; and
3. AMOUNT OF EMPLOYMENT TAX. For the tax periods indicated, we propose changes in the amount
of employment tax, additions to tax, and/or penalties in the amounts shown in the attachment(s) resulting
from the proposed determinations of worker classification and section 530 treatment.
Section 530 of the Revenue Act of 1978 provides relief from employment tax obligations to businesses that
have failed to pay or withhold employment taxes on remuneration paid to individuals because the businesses
did not treat them as employees, if all three of the following requirements are met:
1. For purposes of employment taxes, the business did not treat the individual, or any individual holding a
substantially similar position, as an employee for any period;
2. All required Federal tax returns (including information returns) were filed on a basis consistent with the
business's treatment of the individual as not being an employee; and
Letter 950-C (Rev. 11-2010)
Catalog Number 48701E
3. The business had a reasonable basis for not treating the individual as an employee.
We propose to make the determination that you are not entitled to relief under section 530 because you do not
meet the relief requirements of section 530 with respect to the individual(s) listed or described in the
attachment. The enclosed Publication 1976, Do You Qualifyfor Relief Under Section 530?, provides
additional details on the requirements of section 530.
We have enclosed Form 4666,Summary of Employment Tax Examination, Form 4667, Examination Changes-
Federal Unemployment Tax, and/or Form 4668, Employment Tax Examination Changes Report. These
documents provide details on how we calculated the proposed amount of your additional employment tax
liability that arises from the proposed determination that classifies the individuals) listed or described in the
attachment as employee(s). Please note that these amounts do not include any interest that may apply. If we
propose any adjustments for employment tax that do not involve a worker classification determination, we will
send you a separate letter, Letter 950-D, Employment 30-Day Letter.
If you agree with the proposed changes
1. Sign and date the enclosed agreement form(s), Form 2504-WC,Agreement to Assessment and Collection of
Additional Tax and Acceptance of Overassessment in Worker Classification Cases. Sending us a signed
Form 2504-WC gives us permission to assess the proposed amounts. Signing Form 2504-WC will not
prevent you from filing a claim for refund if you later believe you are entitled to a refund. It will not prevent
us from later determining, if necessary,that you owe additional tax; nor extend the time provided by law for
either action.
2. Return the signed Form 2504-WC to us.
3. Enclose payment for the employment tax and additions to tax and penalties due. Make your check or money
order payable to the United States Treasury. We will bill you for applicable interest, if any. If you pay
now, you will limit the amount of any interest,additions to tax, and penalties charged to your account. If
you agree with the proposed changes but cannot pay the full amount, we will bill you for the unpaid amount.
You may qualify for interest-free treatment if the amounts underreported do not relate to an issue that was
raised in an examination of a prior period and if you did not knowingly underreport your employment tax
liability. In order for the adjustment to be entirely interest-free, you must pay the amount due when you
submit the signed Form 2504-WC. Otherwise, interest will accrue from the date you submit the signed
Form 2504-WC. Even if payment is not made until after receipt of notice and demand, you are nevertheless
entitled to interest-free treatment up to the date you submit the signed Form 2504-WC; however, interest will
accrue from the date the signed Form 2504-WC is submitted until the date of payment.
Please refer to Publication 3498, The Examination Process, for payment options. If you are a debtor in a
bankruptcy case,payment should only be made in accordance with the Bankruptcy Code.
If you do not agree with the proposed changes
1. You may request a meeting or telephone conference with the supervisor of the IRS contact person identified
on the front page of this letter. If you still do not agree after the meeting or telephone conference, you can:
2. Request a conference with our Appeals Office. If you want to have a conference with an appeals officer,
you will need to submit either a small case request or a formal written protest with the IRS contact person
Letter 950-C (Rev. 11-2010)
2 Catalog Number 48701 E
narned in this letter. Based on the total changes to your employment tax for each referenced tax return for
the tax periods indicated, we have indicated whether you need to submit either a small case request or a
formal written protest. Note: If we've proposed any adjustments for employment tax for a referenced tax
return and tax period that do not involve a worker classification determination (as reflected in a separate
letter),we've included those proposed adjustments in tax (including additions to tax and penalties) in
computing the total amount. See the box checked below:
® Small case request. If you want to have a conference with an appeals officer, you can submit a small
case request. Since the total amount of the proposed changes to your tax, additions to tax, and penalties
is $25,000 or less for each referenced tax return for a tax period, you can send us a letter requesting
consideration by Appeals. Indicate the issues you do not agree with and the reasons why you do not
agree. If you do not want to write a separate letter, you can complete the enclosed Form 13683,
Statement of Disputed Issues, and return it to us.
❑ Formal protest. If you want to have a conference with an appeals officer, you must submit a formal
written protest. Since the total amount of the proposed changes to your tax, additions to tax, and
penalties is more than $25,000 for any referenced tax return for a tax period, you must submit a formal
protest. Note: If more than one tax period is involved and any tax period exceeds the $25,000 threshold,
you must submit a formai written protest for all periods involved. Form 13683 cannot be used to make a
formal protest.
If you request a conference with our Appeals Office, an appeals officer will call you (if necessary) for an
appointment to take a fresh look at your case. The Appeals Office is an independent office and most disputes
considered by the Appeals Office are resolved informally and promptly. By requesting a conference with our
Appeals Office you may avoid court costs(such as the Tax Court fling fee)and resolve the matter sooner.
The requirements for filing a formal protest are explained in the enclosed Publication 3198. The publication
also includes information on the Declaration of Taxpayer Rights and the IRS Collection Process.
What happens if you do not reach an agreement with our Appeals Office or if you do not respond to this
letter?
If you do not reach an agreement with our Appeals Office or if you do not respond to this letter, we will send
you Letter 3523 called the Notice of Determination of Worker Classification, that will tell you how to obtain
Tax Court Review of your case. The Notice of Determination of Worker Classification is the legal notice that is
required to begin a proceeding for determination of employment status in the United States Tax Court. The
Notice of Determination of Worker Classification provides a taxpayer with the right to go to the United States
Tax Court, but the taxpayer may choose not to do so. After the receipt of a Notice of Determination of Worker
Classification, you cannot pay your employment tax liability without interest, even if an interest-free adjustment
would have been otherwise available. This letter is NOT the Notice of Determination of Worker
Classification.
Note: You will not receive a Notice of Determination of Worker Classification if you agree to the proposed
changes by signing the Form 2504-WC. Tax Court review is not available for agreed cases. Tax Court review
can only be sought if there is a controversy with respect to the proper amount of tax under the determinations of
worker classification and/or section 530 issues, i.e.,an unagreed case. You may seek judicial review after the
employment tax is assessed by filing a refund suit in district court or in the United States Court of Federal
Claims. Please note that before a refund suit can be filed,you must pay the IRS the amount of employment tax
Letter 950-C (Rev. 11-2010)
3 Catalog Number 48701E
that relates to one worker for one tax period and file a claim for refund with the IRS. If the claim for refund is
denied (or the IRS does not respond to the refund claim within six months), you may file a refund suit in district
court or the United States Court of Federal Claims and challenge the employment tax assessment.
If you have any questions about this letter,you may write to the IRS contact person whose name is shown on
the front page of this letter. If you write,please include your daytime telephone number, the best time for us to
call you if we need more information, and a copy of this letter to help us identify your account. Keep the
original letter for your records.
If you prefer, you may call the IRS contact person at the telephone number shown on the front page of this
letter. If this number is outside your local calling area, there may be a long distance charge to you. You may
call the Business and Specialty Tax Line 1-800-829-4933 or call or visit your local IRS office to obtain general
information,bort the IRS contact person at the telephone number on the front page of this letter is most familiar
with your case.
You also have the right to contact a Taxpayer Advocate. The Taxpayer Advocate Service (TAS) is an
independent organization within the IRS whose employees assist taxpayers who are experiencing economic
harm, who are seeking help in resolving tax problems that have not been resolved through normal channels, or
who believe that an IRS system or procedure is not working as it should. If you believe you are eligible for
TAS assistance,you can reach them by calling the TAS toll-free case intake line at 1-877-777-4778 or
TTY/TDD 1-800-829-4059. For more information, go to www.irs.aov/advocate.
If we propose any adjustments for employment tax that do not involve worker classification issues, you will
receive a separate letter. Such adjustments are not subject to Tax Court review.
MAIL ALL RESPONSES TO:
Internal Revenue Service
1700 Palm Beach Lakes Boulevard
West Palm Beach, FL 33401
An envelope is enclosed for your convenience.
Thank you for your cooperation.
Sincerely yours,
l`
Enclosures: Michael
FSLG Specialist
Copy of this letter
ormT%6-,Ar-
Examination
%6-,A-
Examination Report
GZ1 Fortn 2504-WC
GZl Form 4666
❑ Form 4667
V Form 4668
❑ Form 13683
Publication 1976
Publication -44" sY,t 6
Envelope Letter 950-C (Rev. 11-2010)
4 Catalog Number 48701 E
Date Received by
Farm 2504-WC Department of the Treasury-Internal Revenue Service Internal Revenue
Service
(February 2014) Agreement to Assessment and Collection of Additional Tax and Acceptance
of Overassessment in Worker Classification Cases
(Employment Tax)
Taxpayer(s)name DI131A SSNIEIN
Village of North Palm Beach 59-6017984
Address of taxpayer(s)(number,street) City/Town State ZIP code
501 US Highway 1 North Palm Beach FL 33408
Adjustment to Tax, Credits and Penalties
Tax Period Ended Return Farm Kind of Tax and Internal Amount of Tax Credit Increase(Decrease) Penalty
number Revenue Code Section
2015 941 IRC 3101,3111,3402 $ 11,592.72 $ - $
Total 11,592.72 OAO 0.00
I consent to the immediate assessment(Increase in tax and penalties andlor decrease in credits)and the collection of any such amounts. In addition, I
accept any overassessment(decrease in tax and penalties andlor increase in credits)shown above. I am waiving the restrictions on assessment
provided in sections 7436(d)and 6213(x)of the Internal Revenue Code of 1986.
Sign Date:
Here
Sign Date:
Here w._..
Sign B r Title:
Here
r/2-446.1--" Ali` '114 elle_':, t4✓ l
. :'. .
Note:
If you consent to the assessment of the amounts shown in this agreement,your signature will expedite our adjustment to your account. Your consent will
not prevent you from filing a claim for refund(after you have paid the tax)if you later believe you are entitled to a refund. It will not prevent us from later
determining, if necessary,that you owe additional tax; nor extend the time provided by law for either action.
Who Must Sign
If you are making this agreement for a partnership, all partners must sign. However,one partner may sign with appropriate evidence of authorization to
act for the partnership.
For a corporation, enter the officer or officers of the corporation followed by the signature and title of the officer(s)authorized to sign.
For an agent or attorney acting under a Power of Attorney authorization must attach the authorization to this form unless it is already filed with us.
Memo: Abatement amount under IRC 3402(d)and/or IRC 3102(f)(3)-See explanation on Form 4666
Return Farm Return Form
Tax Period Ended Number IRC Code Credit for Abatement Tax Period Ended Number IRC Code Credit for Abatement
Form 2504-WC(Rev.2-2014) Catalog Number 3320202 publish.no.irs.gov Department of the treasury-Internal Revenue Service
Form 4666 Department of the Treasury-Internal Revenue Service
(aev Mamh2t I Summary of Employment Tax Examination
Name and Address of Employer Fmployer Identification Number Date of Report
Village of North Palm Beach 59-6017984 5/2212017
501 US Highway 1 Type of Report
North Palm Beach FL 3340$ Dettnquent lax Increase(Decrease)in Tax
(Return not',led) X (Return filed)
X Agreed titers repon is soCiea r,resew end you M]be-bbad by
the.Duevtor wFen rt rs acceptetll
Una reed
Following is a summary of the results of my examination of your returns as shown on the attached pages of this report_
Tax,Credits and Penalties
a b c d e 1
Calendar Year Return Form Delinquent Tax,Increase Increase(Decrease)in PenaltyTotal Adjustment and Penalties Page number
Number (Decrease)in Tax Allowed Credits Code Section Amount (c+d+e) of Report
2015 941 11,592.72 - 11,592.72
Total 11,592.72 .,¢: e. 11,592.72
Other Information
The examination of your employment tax returns as reflected on this Agreement included an examination for employment tax purposes of whether golf,tennis,
dance,pool,fitness and karate instructors,a medical director and entertainers should be treated as employees of the taxpayer. Section 530 of the Revenue Act
of 1978 as amended by Section 1122 of the Small Business Job Protection Act of 1996 provides that taxpayers may rely on a prior audit commenced after
December 31, 1996,when the audit included an examination for employment tax purposes of whether the individual involved(or any individual holding a position
substantially similar to the position held by the individual involved)should be treated as an employee of the taxpayer. Based upon this examination,you may rely
only on the audit of a medical director and entertainers that did not result in a reclassification for purposes of the prior audit safe haven for satisfying the
reasonable basis requirement of Section 530.
This does not constitute an income tax examination.
Form 2504-WC IRC section 7436 issues
Examinrq Oficar's SignaNreJlr�" '`.. Examin,ng tlK�cer�s lD4 Area
Michael Moore 1000875879 Gulf Coast
Catalog Number 41874S wtiw+.irs.gov Form 4666(Rev.03-2011)
Form 4668 Department of the Treasury-Internal Revenue Service Return Form number
(April 2014) Employment Tax Examination Chan es Report 941
Name of Employer Employer Identification number Calendar year
Village of North Palm Beach 59-6017984 2016
Address of Employer Total tax plus penalty,or(decrease)in tax
601 US Highway 1 Last quarter of this
North Palm Beach $ 11,592.72 examination
FL 33408 Total increase or(decrease)in credits December
$
Examination discussed with(Name and title) Agreed(Subject to acceptance of the Director)
Andy Likasik,Village Manager
Unagreed
(b) {c} d) (e)
1st 2nd 3rd 4th
Quarter Quarter Quarter Quarter
1 . Total Social security and Medicare tax adjustment(from
Schedule of Adjustments,Line 10) 2,491.13 2,491.13 2,491.13 2,491.13
2. Social security and Medicare wage adjustment under IRC
3121(q)(from Schedule of Adjustments,Line 11) _ _
3 Increase(decrease)in tax exemption on exempt wages/tips
(From Schedule of Adjustments,tine 13) _ -
Total Income tax withholding(from Schedule of
4 Adjustments,Line 20) 407,05 407.05 407.05 407.05
Delinquent tax or increase(decrease)in tax(Lines 1,2 and
5. 4 minus/plus Line 3) 2,898.18 2,898.18 2,898.18 2,898.18
Net increase(decrease)in credits(from Schedule of
6 Adjustments,Line 26)
7. Penalty code section 6651(a)(1)
8 Penalty code section 6651(a)(2)
9, Penalty code section 6656
10. Penalty code section
11 . Total penalty(sum Lines 7,8,9 and 10) $ $ $
12, Maximum tax available for abatement under IRC 3402(d) $ $ $ $
13. Maximum tax available for abatement under IRC 3102(0(3) $ $ $ $
Furnish Form W-2(Wage and Tax Statement)or Form W-2c(Corrected Wage and Tax Statement)on or before January 31,2018 to each of the one employees
whose wages are adjusted by this report.
File Forms W-2 with Form W-3(Transmittal of Wage and Tax Statements)or Forms W-2c with Form W-3c(Transmittal of Corrected Wage and Tax Statements)
on or before January 31,2018 with the Social Security Administration(SSA).
IRC 6721 and 6722 provide penalties for failure to file and failure to furnish information returns. You must file the information returns electronically if you are
required to file 250 or more returns. To obtain specifications for e-filing your returns,visit the SSA's website at www.socialsecurity.gov/employer. If filing paper
returns,file with the SSA at the appropriate address in the General Instructions for Forms W-2 and W-3(Including Forms W-2AS,W-2CM,W-2GU,W-2VI,W-
3SS,W-2c,and W-3c).
USPS to: Other Courier Service to:
Social Security Administration Social Security Administration
Direct Operations Center Direct Operations Center
Wilkes-Barre, PA 18769-0001 Attn: W-2c Process
1150 E. Mountain Drive
Wilkes-Barre, PA 18702-7997
Form 2504-WC IRC section 7436 issues
Examiner's signature Examiner's ID# Group Number Area Date
Michael Moore ZTZ&A 1 1000875879 7252 Gulf Coast May 22,2017
Catalog Number 232752 www.irs.gov Form 4668(Rev.4-2014)
Schedule of Adjustments
Name of Employer Employer identification number Calendar year
Village of North Palm Beach 59-6017984 2015
Adjustment to FICA Wages and Tax
(a) (b) Ic) (d) (e)
Applicable i st 2nd 3rd 4th
IRS Ref. Rate Quarter Quarter Quarter Quarter
1 Social security and Medicare wage adjustment subject to 004 12.4%
tax under IRC 3101 and 3111
073 2.90% - - -
2 Social security and Medicare wage adjustment subject to 7.44% 27,136.50 27,136 50 27,136.50 27,136.50
tax under IRC 3509(a) 079
7.74°!n 27,13fi 50 27,136.50 27,136.50 27,136.50
3 Social security and Medicare wage adjustment subject to 8.68% -
tax under IRC 3509(b) 079
2.03°l0 - - -
4 Social security and Medicare tip adjustment subject to 005 6.20!0
tax under IRC 3101 and 3111
073 1.45%
5 Additional Medicare wage and/or tip adjustment subject
to tax under IRC 3101(b)(2) 074
0.90°!° - - -
6 Additional Medicare wage and/or tip adjustment subject
to tax under IRC 3101(b)(2)and 3509(a) 079
0.18°!° - - -
7 Additional Medicare wage and/or tip adjustment subject
to tax under IRC 3101(b)(2)and 3509(b) 079
0.36°!° - - -
8 Other adjustments to Social Security and Medicare
wages
9 Other adjustments to Social Security and Medicare
wages
10
Total social security and Medicare tax
(lines 1 through 8 x rates plus/minus line 9) 112 $ 2,401.13 $ 2,491 13 $ 2,491.13 $ 2.491 13
11 Social Security and Medicare tax adjustment under
3121(q) 114
12 Increase(decrease)in exempt wages/tips paid to
qualified employees under IRC 3111(d) 115
13 Increase(decrease)in tax exemption on wages/tips on
Line 12(Line 12 x rate) 116
Catalog Number 23275Z www.irs.gov Form 4668(Rev.04-2014)
Schedule of Adjustments Continued
Name of Employer Employer Identification number Calendar year
Village of North Palm Beach 59-5017984 2015
Adjustment to Wages and Tax for Income Tax Withholding
{a} {b) (c) (d) (e)
Applicable 1st 2nd 3rd 4th
IRS Ref. Rate Quarter Quarter Quarter Quarter
14 Income withholding wage adjustment subject to tax under
section 3402 25.00%
15 Income tax withholding wage adjustment subject to rates
under IRC 3509(a) 079 1.50% 27,136.50 27,136.50 27,136.50 27,136-50
16 Income tax withholding wage adjustment subject to rates
under IRC 3509(b) 079 3.00% - -
17.Other income tax withholding wage adjustment
18 Actual income tax withheld but not previously reported
19, Other adjustment to income withholding
20 Total income tax(Lines 14,15,16,17 x rates plus Line
18 plus/minus Line 19) 111 $ 407.05 $ 407.05 $ 407.05 407.05
Adjustment to Credits Against the Tax
21 Increase(decrease)in COBRA premium assistance
payments under IRC 6432 228
22 Increase(decrease)in Advance Earned Income Credit
under IRC 3507 7661767
Increase(decrease)in exempt wagesftips paid to
23. qualified employees March 19-31,2010 under IRC 117
3111(d)(5)
24 Increase(decrease)in credit for exempt wagesttips on
Line 23(Line 23 x rate) 286
E l f I
25. Increase(decrease)in other credits
26. Nei increase(decrease)in credits(sum of Lines 21.22, � �
24.and 25)
Catalog Number 232752 WVNI.irs.gov Form 4668(Rev.04-2014)
Department of the Treasury-Internal Revenue Service
Form 4491 Closing Agreement On Final Determination Covering Specific
{Mayy 2013} Matters Regarding Worker Classification
Under section 7121 of the Internal Revenue Code("IRC"), Village of North Palm Beach , 501 US Highway 1, North Palm
Beach, FL 33408,Taxpayer Identification Number 59-6017984, ("taxpayer")and the Commissioner of Internal Revenue
("Commissioner")make the following closing agreement:
WHEREAS, there is a dispute between the parties as to whether certain workers classified by taxpayer as Golf, tennis,
dance, pool,fitness and karate instructors are independent contractors or employees of taxpayer for purposes of
federal income tax withholding, Federal Insurance Contributions Act(FICA)and Federal Unemployment Tax Act
(FUTA)taxes("federal employment tax');
WHEREAS, the taxpayer is presently treating the Golf,tennis, dance, pool,fitness and karate instructors as
independent contractors;
WHEREAS, the taxpayer has timely filed Forms 1099 for each of its Golf,tennis,dance, pool, fitness and karate
instructors for all applicable periods from January 1,2015 through December 31, 2015, in accordance with the
provisions of paragraph 3.02 of Rev. Proc. 85-18, 1985-1 C.B. 518,and Rev. Rul. 81-224, 1981-2 C.B. 197; and
WHEREAS, the parties wish to resolve this dispute for all Golf,tennis, dance, pool, fitness and karate instructors
engaged by the taxpayer on or after January 1,2014
NOW IT IS HEREBY DETERMINED AND AGREED for federal employment tax purposes that:
(1) The Internal Revenue Service will assess and the taxpayer will pay the following amounts to the United States
Government in full discharge of any federal employment tax liability it may owe for the periods shown below resulting
directly or indirectly from its failure to pay and/or withhold federal income tax, FICA, or FUTA taxes on the payments
to its Golf,tennis, dance, pool,fitness and karate instructors:
Period Type of Tax Amount to be Assessed
Tax Penalties
2015 FICA and Income Tax $11,592.72 $0.00
(2) The Internal Revenue Service will not disturb taxpayer's classification of such Golf, tennis, dance, pool,fitness and
karate instructors for federal employment tax purposes for any period from January 1, 2014 through September 30,
2017.
(3) Beginning October 1, 2017,and for all periods thereafter, Golf,tennis,dance, pool,fitness and karate instructors and
persons performing equivalent duties regardless of taxpayer's job titles will be treated as employees for all federal
employment tax purposes.
Catalog Number 62648W www.irs.gov Form 14491 (5-2013)
Closing Agreement With Village mfNorth Palm Beach
(4) The taxpayer waives any right dmay have hmclaim relief under section 53Uofthe Revenue Act of 1978.
(b) IRC Section G2O5shall apply bothe amounts contained inparagraph(1)above, except FUTAtax.
This agreement|sfinal and conclusive except:
(1)the matter it relates to may be reopened in the event of fraud, malfeasance, or misrepresentation of material facts;
(2)it|osubject tVthe Internal Revenue Code sections that expressly provide that effect begiven totheir provisions
(including any stated exception for Code section 7122) notwithstanding any other law or rule of law; and
(3)if it relates to a tax period ending after the date of this agreement, it is subject to any law, enacted after the
agreement date,that applies tuthe tax period.
By signing,the above parties certify that they have read and agreed to the terms of this document.
Taxpayer Village of No,&Palm
By Date signed /
Title
—xpayer's Representative
By =Date signed
Commissioner of Internal Revenue
By IDqte signed
Tide
LQ
v I V I
u2
-7,
7Z LL,
I'd -� OC) r-, Ln -,T C) (4) -A
06
x CO r-� t-- x -1 -41 rj 1 r-i �t I'D Ln �.o Ln 0) in m co 0)
C5 ;f rJ
m Ln en �p 0) Kr 1 Kr C* �'r r-- loo no "0 r- Ln uo r- F--- a,
�T
in
0V?i VII V)L -vt -�n 1 in v)- -,A
V�
-i kD 0 to Ln M M 00 (n 0 (n W fn rn (D 0)
i x 0o ZY Lo i ff) x (5 m w i co ko l 6 en r-4 I oo m rj 4 N r-4 �t r-, --i
F
4 ,6 o6 ci of 4 QS q zt r-, r\, cp co 5 00 0 r-� f 1 --4
r14 j r*4 M IN rN M W
jyy J/T if1 Ify 4/y if) J/'} t/T jf} jj,} ift tra tf> 4_1,> qjF
al
Q 0 19,
ON
Ln -4 N i
i I i i CD
io:c CD C) (D I C) C> (D C� C> C) CD CD CD CD C) C)
Le-I Ln Lh Ln Lr, Ln Ln n Ln Ln Ln Lr) U� L,� Lj� L,1
_I rj _i rt _i 'i _i
W-
m ro M CO -r~: M Lrl 0 0 tD
en Lq Lq I Lq 1 t'-: N I N 'I to to o In
X C) f'4 Co '.4 M 00 --t "D Q "'D Co t--
m 0 r1 O LD en Ln _0 k ZD CO
C) (,4 Ln (31 (N Ln cr)
E
-V)r -VV)L -V'r V,'- -ulk -ul ilrt h l-Vi• -(n -Lr`r V. l tn
e- -e
0 0
OR i IOIR 100,
Lj� f_j Lj Fj 00 00 00 00 00 loo loo 1 00 loo 0 00 00 00 1 CO CO
m rl rn 1 r 'I rH i H
C� -I
03 00
r-q r-I I
Ln LL. U.
CQ Cl 0 0 0 C) 0 0 0 C> C> 0 0 0 0 C) 0 0
44 r- 0 rq q q q r_>
of
C! oho C� C! q C! C� C) 0 0 0
. , . . .
a,+ r-1 M Ln C-4 r -� C) Ln W (14 M Ln C,4 M fNtn r� LD
w r� r, r,
00 Ln N 't 0 C m m (N d' N ,o r -c* ;& (14 T-A to t--i dt
oll 0) to r-4 rl z 't CN� r-, (N f-, in to r, (A -zt to r-. m 00 r-I r, U-1
o Ln, 0 T-i r4 rj 1 1
ui C- m -;F ce ke 1� Cf 06
r: rq (14 C>
-tn in. 114 t4 in. in 4^ V} Q11. t4 <n 4A, -Ln
Uj
F-
W) Z 0z
cl: V) uj
NCL
0 bb — Z < 0 < z 0 CIL
z m z w cc 0 U, z a- 0
w < = 3: *
0 0 z m ;5 u
LL 3: > u D
0 . 1
4-9 2i V)
r- z oLU co <
MO 0 Lu >
w 4) cc cr- 0) >- uj = Lij < m >
r= R Z U 0 z U z <
tn --� Oz � z ;;� Ono ELUW
2 13-1 u LLJ
06 LLJ irf < LL, Ld L,
Z Z 4A m <
m < m Ul LU 0-
CL z W z 0 z z W u Uj z
Lij < z z o w w w LU < g
-1 0 < LL V)
A Cz I < u u 0 0 -j 2 2 CL
m Ln 0 N ri w to a kD TH d w Ict r- m m d 00 r.
Mm N m .4t m m 0 h r a ill N (D 0 (.0 h(,Y) a) 0) C) m Ln m iD (D Ln w o 00 m H H 0) rl, a)
z T L�l 9 �r� z "? r� L� T TV 9 19 lP 9 Ln 7 T 9
:T -1 to rl, 0 a 0 rH 00 0 N 0 N r� 00 0) rq to C to in
M P� 19 ll� Ln N tD M zj, r-q 4.0 io M C> A et' 0 *It IT lZr
ob r� Ln -1 0 rA to ,tt a w b N m 0 rN w a -4 N Ln
Ln N Ln Ln r- Ln at r. m RT 19t ICT
11 C� W Ln fn C14 I�r to - ON
ct 04) fy' 'o
0 n Ln 11 ,NP,4,