Legal Opinion

Leticia C. Santos v. Commissioner

United States Tax Court

Decided June 17, 2020No. 27693-14Unpublished

1Opinion of the Court

T.C. Memo. 2020-88

UNITED STATES TAX COURT LETICIA C. SANTOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27693-14. Filed June 17, 2020. Roger S. Davis, for petitioner. Marie E. Small and Linda P. Azmon, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION ASHFORD, Judge: This case is before the Court on a petition for redetermination of employment status pursuant to section 7436.1 In a notice of 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules…

2Cases cited16 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Professional & Executive Leasing, Inc., an Idaho Corporation, Petitioner v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  3. Professional & Executive Leasing v. CommissionerUnited States Tax Court · 1987
  4. Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
  5. Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003

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