3P Delivery, Inc. v. Employment Department Tax Section

In this unemployment tax case, petitioner 3P Delivery, Inc. (3PD), an interstate motor carrier, seeks judicial review of a final order of an administrative law judge (AL J) of the Office of Administrative Hearings determining that 3PD had taxable payroll for all four quarters of 2006 and 2007 and affirming unemployment tax assessments by the Employment Department (the department). 3PD contends that the ALJ erred in determining that delivery services provided to 3PD by “owner-operator” truck drivers pursuant to a “leaseback” arrangement constituted taxable employment. Rather, 3PD asserts,…