Cheryl A. Mayfield Therapy Ctr. v. Comm'r
United States Tax Court
Massage therapists, cosmetologists, and nail technicians (service providers) operated on the premises of Ps' spa. Ps generally charged each service provider weekly "booth rent" equal to the greater of approximately $80 base rent or 25 percent of the service provider's gross revenues. Ps contend that they had a landlord/tenant relationship with the service providers. R determined that the service providers were Ps' employees.
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Massage therapists, cosmetologists, and nail technicians (service providers) operated on the premises of Ps' spa. Ps generally charged each service provider weekly "booth rent" equal to the greater of approximately $80 base rent or 25 percent of the service provider's gross revenues. Ps contend that they had a landlord/tenant relationship with the service providers. R determined that the service providers were Ps' employees. Held: The service providers were independent contractors.
1Opinion of the Court
CHERYL A. MAYFIELD THERAPY CENTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
ARDMORE DAY SPA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cheryl A. Mayfield Therapy Ctr. v. Comm'r
Docket Nos. 9156-07, 9157-07
United States Tax Court
T.C. Memo 2010-239; 2010 Tax Ct. Memo LEXIS 276; 100 T.C.M. (CCH) 376; Unemployment Ins. Rep. (CCH) P14,760C;
October 28, 2010, Filed
Decisions will be entered under Rule 155.
Massage therapists, cosmetologists, and nail technicians (service providers) operated on the premises of Ps' spa. Ps generally charged each service provider…
2Cases cited14 opinions
- Nationwide Mutual Insurance v. DardenSupreme Court of the United States · 1992
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Ingram v. United StatesSupreme Court of the United States · 1959
- Child Labor Tax CaseSupreme Court of the United States · 1922
- United States v. WurtsSupreme Court of the United States · 1938
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