Legal Opinion

American Business Service Corp. v. Commissioner

United States Tax Court

Decided October 3, 1989No. Docket No. 33003-86Published

T Corp. had between 80 and 128 permanent employees and approximately 13,000 temporary personnel. Its business was supplying its customers with the services of its temporary personnel for a fee. The permanent workers were employed in petitioner's central and branch offices. T paid the temporary workers their wages or salaries and issued W-2 Forms to them.

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T Corp. had between 80 and 128 permanent employees and approximately 13,000 temporary personnel. Its business was supplying its customers with the services of its temporary personnel for a fee. The permanent workers were employed in petitioner's central and branch offices. T paid the temporary workers their wages or salaries and issued W-2 Forms to them. It maintained a profit-sharing plan for all its personnel who worked a minimum of 20 hours a week, both permanent and temporary; the plan qualified under sec. 401(a), and T took deductions under sec. 404 for its contributions to the plan. It…

1Opinion of the Court

American Business Service Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

American Business Service Corp. v. Commissioner

Docket No. 33003-86

United States Tax Court

93 T.C. 449; 1989 U.S. Tax Ct. LEXIS 134; 93 T.C. No. 36;

October 3, 1989October 3, 1989, Filed

Decision will be entered for the petitioner.

T Corp. had between 80 and 128 permanent employees and approximately 13,000 temporary personnel. Its business was supplying its customers with the services of its temporary personnel for a fee. The permanent workers were employed in petitioner's central and branch offices. T…

2Cases cited5 opinions

  1. Sanford v. CommissionerUnited States Tax Court · 1968
  2. William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
  3. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  4. American Business Service Corp. v. CommissionerUnited States Tax Court · 1989
  5. Termicold Corp. v. United StatesUnited States Court of Claims · 1983

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