Legal Opinion

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

United States Tax Court

Decided August 4, 2003No. 5077-01PublishedCited by 76 opinions

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

Laro, Judge:

Petitioner petitioned the Court under section 7436(a)1 to redetermine the following employment tax liabilities and additions thereto determined by respondent:

Additions to tax

Tax period Employment ended tax Sec. 6651(a)(1) Sec. 6656

3/1995 $2,356.20 $589.05 $117.81

6/1995 2,004.30 501.08 100.22

9/1995 1,774.80 443.70 88.74

12/1995 2,627.85 656.96 80.68

3/1996 1,300.50 325.13 65.03

6/1996 2,080.80 520.20 104.04

9/1996 841.50 210.38 42.08

12/1996 2,191.11 212.91 70.27

3/1997 1,942.48 485.62 97.12

6/1997 1,942.48 485.62 97.12

9/1997 1,942.28 - 0 - 97.12

12/1997 1,942.48 -0-97.12

3/1998 1,785.89…

2Cases cited34 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

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

3Cited by76 opinions

  1. Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
  2. Domulewicz v. Comm'rUnited States Tax Court · 2007
  3. Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
  4. Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
  5. Frank T. Voelker v. Catherine M. NolenCourt of Appeals for the Seventh Circuit · 2004

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

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