Charlotte's Office Boutique, Inc. v. Commissioner

121 T.C. No. 6

UNITED STATES TAX COURT CHARLOTTE’S OFFICE BOUTIQUE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5077-01. Filed August 4, 2003. 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…