Legal Opinion

Joseph M. Grey Pub v. Commissioner IRS

Court of Appeals for the Third Circuit

Decided April 7, 2004No. 02-4417, 03-2756, 03-2757UnpublishedCited by 17 opinions

1Opinion of the Court

OPINION OF THE COURT

SMITH, Circuit Judge.

The Internal Revenue Service (“IRS”) classified an officer and shareholder of each of the appellant corporate taxpayers as an employee for purposes of federal employment taxes. The Notice of Determination sent to each of the taxpayers and advising of them of this classification also indicated that the taxpayer was not entitled to relief under Section 530 of the Revenue Act of 1978. 1 As a result, each of the corporate taxpayers was assessed employment taxes for its respective employee under the Federal Insurance Contributions Act (“FICA”), 26 U.S.C. §§…

2Cases cited3 opinions

  1. Harris v. City of PhiladelphiaCourt of Appeals for the Third Circuit · 1994
  2. Pnc Bancorp, Inc., Successor to First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16002) Pnc Bancorp, Inc., Transferee of Assets of First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16003) Pnc Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) Pnc Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) Pnc Bancorp, Inc., as (I) Successor to First National Pennsylvania Corporation, (Ii) Transferee of Assets of First National Pennsylvania Corporation, (Iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (Iv) Transferee of Assets of United Federal Bancorp, Inc., and SubsidiariesCourt of Appeals for the First Circuit · 2000
  3. Nu-Look Design, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2004

3Cited by17 opinions

  1. Anderson v. Comm'rUnited States Tax Court · 2004
  2. DiDonato v. Comm'rUnited States Tax Court · 2013
  3. Keller v. Comm'rUnited States Tax Court · 2012
  4. Cent. Motorplex, Inc. v. Comm'rUnited States Tax Court · 2014
  5. D & R Fin. Servs. v. Comm'rUnited States Tax Court · 2011

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