(plaintiff provides medical treatment at various locations and hires physicians under five-year contracts in exchange for advances during the first two years of employment which must be repaid if employment ceases within five-year term; while advances accrue interest, physicians not required to pay interest; plaintiff did not withhold income or payroll tax on advances and advances not reported on Form W-2 but were reported on Form 1099-Misc. upon date amount no longer needed to be repaid; IRS assessed withholding and FICA tax plus interest for total amount over $600,000; court determined that advances were compensation for services; no intention that repayment be made, but that physicians would work five-year term; no fixed schedule for repayment at time agreements signed; advances were wages subject to withholding of employment and income tax).