Veterinary Surgical Consultants, P.C. v. Comm'r
United States Tax Court
P, an S corporation, distributed all of its net income to A, its sole shareholder and president. A performs substantial services for P. On his Forms 1040, A reported P's net income as nonpassive income from an S corporation. R issued to P a Notice of Determination Concerning Worker Classification Under Sec. 7436, determining that A was an employee of P for purposes of Federal employment tax.
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P, an S corporation, distributed all of its net income to A, its sole shareholder and president. A performs substantial services for P. On his Forms 1040, A reported P's net income as nonpassive income from an S corporation. R issued to P a Notice of Determination Concerning Worker Classification Under Sec. 7436, determining that A was an employee of P for purposes of Federal employment tax. HELD: A is an employee of P for purposes of Federal employment tax pursuant to sec. 31.3121(d)-(1)(b), Employment Tax Regs., because A is an officer who performs substantial services for P and receives…
1Opinion of the Court
VETERINARY SURGICAL CONSULTANTS, P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Veterinary Surgical Consultants, P.C. v. Comm'r
No. 2500-99
United States Tax Court
117 T.C. 141; 2001 U.S. Tax Ct. LEXIS 45; 117 T.C. No. 14;
October 15, 2001, Filed
Decision will be entered for respondent and in accordance with the parties' stipulations as to amounts.
P, an S corporation, distributed all of its net income to
A, its sole shareholder and president. A performs substantial
services for P. On his Forms 1040, A reported P's net income as
nonpassive income from an S corporation.
R issued to P a…
2Cases cited9 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
- Spicer Accounting, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1990
- Antonio R. Durando Naomiann N. Durando v. United StatesCourt of Appeals for the Ninth Circuit · 1995
- Veterinary Surgical Consultants, P.C. v. Comm'rUnited States Tax Court · 2001
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