Legal Opinion

Reflectxion Resources, Inc. v. Commissioner

United States Tax Court

Decided August 3, 2020No. 12017-16Unpublished

1Opinion of the Court

T.C. Memo. 2020-114

UNITED STATES TAX COURT REFLECTXION RESOURCES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12017-16. Filed August 3, 2020. P, a medical staffing agency, hired therapists to work for client medical facilities. P entered into a professional services agreement with G for 11 calendar quarters, during which G paid the therapists and filed employment tax returns reporting itself, not P, as their employer, pursuant to I.R.C. sec. 3401(d). For the next 5 calendar quarters, P paid the therapists itself and filed the employment tax returns. In all 16…

2Cases cited13 opinions

  1. Aetna Life Insurance v. HaworthSupreme Court of the United States · 1937
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Malowney v. Federal Collection Deposit GroupCourt of Appeals for the Eleventh Circuit · 1999
  4. Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
  5. Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003

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