Legal Opinion

Scott Labor, LLC v. Comm'r

United States Tax Court

Decided September 29, 2015No. Docket No. 22360-12LUnpublished

Until it ceased operations in April 2007, P was a single-member LLC owned and managed by B who, because P was a disregarded entity under the "check-a-box" regulations, reported P's results on a Schedule C, Profit or Loss From Business, included in B and his wife's joint individual income tax returns.

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Until it ceased operations in April 2007, P was a single-member LLC owned and managed by B who, because P was a disregarded entity under the "check-a-box" regulations, reported P's results on a Schedule C, Profit or Loss From Business, included in B and his wife's joint individual income tax returns. On its Forms 941, Employer's Quarterly Federal Tax Return, filed for 2005, 2006, and the first quarter of 2007, P offset the employment taxes due with respect to its employees' wages by the advance earned income credits (AEIC) allegedly paid to those employees. Under the Combined Annual Wage…

1Opinion of the Court

SCOTT LABOR, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Scott Labor, LLC v. Comm'r

Docket No. 22360-12L.

United States Tax Court

T.C. Memo 2015-194; 2015 Tax Ct. Memo LEXIS 203;

September 29, 2015, Filed

Decision will be entered under Rule 155.

Until it ceased operations in April 2007, P was a single-member LLC owned and managed by B who, because P was a disregarded entity under the "check-a-box" regulations, reported P's results on a Schedule C, Profit or Loss From Business, included in B and his wife's joint individual income tax returns. On its Forms 941, Employer's Quarterly…

2Cases cited24 opinions

  1. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  2. Goza v. CommissionerUnited States Tax Court · 2000
  3. Sego v. CommissionerUnited States Tax Court · 2000
  4. Woodral v. CommissionerUnited States Tax Court · 1999
  5. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006

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