Legal Opinion

Charlotte's Office Boutique, Inc. v. Comm'r

United States Tax Court

Decided August 4, 2003No. 5077-01Published

P is a C corporation owned equally by O and her husband. P petitioned the Court under sec. 7436(a), I.R.C., to redetermine R's determination that P was liable for unreported 1995 through 1998 employment taxes and additions to tax under secs. 6651(a)(1) and 6656, I.R.C.

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P is a C corporation owned equally by O and her husband. P petitioned the Court under sec. 7436(a), I.R.C., to redetermine R's determination that P was liable for unreported 1995 through 1998 employment taxes and additions to tax under secs. 6651(a)(1) and 6656, I.R.C. That determination resulted from R's determination that O received "wages" in the form of payments which P made to O primarily as "royalties" and, for 1995 and 1996, that P also had "Other Workers" who received "wages". R concedes his determination as to the other workers and moves the Court to dismiss this case for lack of…

1Opinion of the Court

CHARLOTTE'S OFFICE BOUTIQUE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Charlotte's Office Boutique, Inc. v. Comm'r

No. 5077-01

United States Tax Court

121 T.C. 89; 2003 U.S. Tax Ct. LEXIS 25; 121 T.C. No. 6; Unemployment Ins. Rep. (CCH) P17,138;

August 4, 2003, Filed

Respondent's motion to dismiss was denied.

P is a C corporation owned equally by O and her husband. P

petitioned the Court under sec. 7436(a), I.R.C., to redetermine

R's determination that P was liable for unreported 1995 through

1998 employment taxes and additions to tax under secs.

6651(a)(1) and 6656, I.R.C. That…

2Cases cited35 opinions

  1. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. Geders v. United StatesSupreme Court of the United States · 1976
  4. Quercia v. United StatesSupreme Court of the United States · 1933
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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