a deficiency notice under section 6212 is sent, or (C) the date on which a notice of determination under section 7436(b)(2) is sent. (4) Reasonable cause exception The requirements of paragraphs (1)(B) and (2)(B) shall be treated as met if the failure to satisfy such requirements is due to reasonable cause and not willful neglect. (5) No restriction on administrative or judicial review Nothing in this subsection shall be construed as limiting any provision of law which provides an opportunity for administrative or judicial review of a determination by the Secretary. (i) Rule of construction Nothing in this section shall be construed as— (1) limiting the ability or right of a service provider, service recipient, or payor to apply any other provision of this title, section 530 of the Revenue Act of 1978, or any common law rules for determining whether an individual is an employee, or (2) establishing a prerequisite for the application of any provision of law described in paragraph (1). (j) Definitions For purposes of this section— (1) Service provider (A) In general The term service provider means any qualified person who performs service for another person. (B) Qualified person The term qualified person means— (i) any natural person, or (ii) any entity if any of the services referred to in subparagraph (A) are performed by one or more natural persons who directly own interests in such entity. (2) Service recipient The term service recipient means the person for whom the service provider performs such service. (3) Payor The term payor means— (A) any person, including the service recipient, who pays the service provider for performing such service, or (B) any third party settlement organization, as defined in section 6050W(b)(3). (k) Regulations Notwithstanding section 530(d) of the Revenue Act of 1978, the Secretary shall issue such regulations as the Secretary determines are necessary to carry out the purposes of this section. . (b) Withholding by payor in case of certain persons classified as not employees