Legal Opinion

Specialty Transport & Delivery Services, Inc. v. Commissioner

Court of Appeals for the Third Circuit

Decided March 12, 2004No. 03-2732Published

1Opinion of the Court

OPINION OF THE COURT

ALDISERT, Circuit Judge.

This appeal from a decision of the United States Tax Court that decided that John Ludlow, an officer and sole shareholder of the taxpayer, Specialty Transport & Delivery Services, Inc. (“Specialty Transport”), was an employee and that the taxpayer was therefore liable for taxes under the Federal Insurance Contributions Act (“FICA”), 26 U.S.C. §§ 3101-3128, and the Federal Unemployment Tax Act (“FUTA”), 26 U.S.C. §§ 3301-3311. We affirm for the rationale and holding set forth in Nu-Look Design, Inc. v. Comm’r of Internal Revenue, 356 F.3d 290 (3d…

2Cases cited5 opinions

  1. 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
  2. Nu-Look Design, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2004
  3. Texas Carbonate Company v. R. L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
  4. Yeagle Drywall Co. v. CommissionerCourt of Appeals for the Third Circuit · 2002
  5. Veterinary Surgical Consultants, P.C. v. CommissionerCourt of Appeals for the Third Circuit · 2004

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