United States v. Porter, 569 F.Supp.2d 862 (S.D. Iowa 2008)

(defendant, maker and seller of nutritional products for swine, dairy and beef cattle, classified salesmen as “independent contractors”, but plaintiff asserted salesmen were “employees” such that defendant was responsible for withholding and remitting employment and unemployment taxes on such persons; additional taxes and interest which defendant failed to pay; as such, plaintiff filed a federal tax lien on defendant’s real property and later moved to foreclose the lien; government’s classification of salesmen as employees upheld, but issues of material fact existed as to whether defendant entitled to Section 530 safe harbor; whether or not innocent spouse relief granted immaterial to issue in case; no fact issues present as to statute of limitations question; defendant’s motion to dismiss denied as is defendant’s motion for jury trial; government’s liens upheld).