Legal Opinion

Burnetta v. Commissioner

United States Tax Court

Decided June 13, 1977No. Docket Nos. 6293-75, 6294-75, 6335-75, 6339-75, 6340-75PublishedCited by 17 opinions

Certain individuals worked daily in the offices of the two petitioner professional corporations, but the workers' records were maintained and their paychecks were issued by a separate payroll service corporation. These individuals were not covered by the professional corporations' respective pension and profit-sharing plans.

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Certain individuals worked daily in the offices of the two petitioner professional corporations, but the workers' records were maintained and their paychecks were issued by a separate payroll service corporation. These individuals were not covered by the professional corporations' respective pension and profit-sharing plans. The professional corporations hired these workers, determined their initial rates of pay as well as any subsequent increases, and retained the right to control them in the performance of their office duties. The pension and profit-sharing plans established by each…

1Opinion of the Court

Forrester, Judge:

In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income tax:

Docket No. Petitioner Taxable year ending Deficiency

6293-75 Edward L. Burnetta, O.D., P.A.. 7/31/70 $915.95

7/31/71 1,612.85

7/31/72 3,085.78

6294-75 Edward L. Burnetta. 12/31/72 3,444.74

6335-75 Charles A. Crockett and Marie Crockett.. 12/31/72 7,594.00

6339-75 Charles A. Crockett, M.D., P.A. 7/31/70 1,879.57

7/31/71 2,908.42

7/31/72 4,008.08

6340-75 Edward L. Burnetta, O.D., P.A., Employees Profit Sharing Trust, Traders National Bank, trustee. 7/31/71 134.88

The issues…

2Cases cited8 opinions

  1. Simpson v. CommissionerUnited States Tax Court · 1975
  2. Packard v. CommissionerUnited States Tax Court · 1975
  3. Hand v. CommissionerUnited States Tax Court · 1951
  4. Ellison v. CommissionerUnited States Tax Court · 1970
  5. James v. CommissionerUnited States Tax Court · 1956

3 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Professional & Executive Leasing v. CommissionerUnited States Tax Court · 1987
  2. Ralph H. Minor and Jackie C. Minor v. United StatesCourt of Appeals for the Ninth Circuit · 1985
  3. Porter v. CommissionerUnited States Tax Court · 1987
  4. United States v. GaramiDistrict Court, M.D. Florida · 1995
  5. Garland v. CommissionerUnited States Tax Court · 1979

12 more not listed; retrieve them via the Exa API.

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