American Business Service Corp. v. Commissioner
United States Tax Court
T Corp. had between 80 and 128 permanent employees and approximately 13,000 temporary personnel. Its business was supplying its customers with the services of its temporary personnel for a fee. The permanent workers were employed in petitioner's central and branch offices. T paid the temporary workers their wages or salaries and issued W-2 Forms to them.
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T Corp. had between 80 and 128 permanent employees and approximately 13,000 temporary personnel. Its business was supplying its customers with the services of its temporary personnel for a fee. The permanent workers were employed in petitioner's central and branch offices. T paid the temporary workers their wages or salaries and issued W-2 Forms to them. It maintained a profit-sharing plan for all its personnel who worked a minimum of 20 hours a week, both permanent and temporary; the plan qualified under sec. 401(a), and T took deductions under sec. 404 for its contributions to the plan. It…
1Opinion of the Court
OPINION
RAUM, Judge:
The Commissioner determined deficiencies in petitioner’s 1980 and 1981 Federal income tax in the amounts of $3,680 and $12,696, respectively. The deficiencies for both years resulted from the disallowance of expense deductions taken by petitioner for the rental of a 53-foot powerboat known as the Americana. The case was submitted on the basis of a stipulation of facts.
During the years at issue, petitioner was a California corporation with a principal place of business in Newport Beach, California, and approximately 25 branch offices located primarily in central and southern…
2Cases cited4 opinions
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Termicold Corp. v. United StatesUnited States Court of Claims · 1983
3Cited by4 opinions
- Texas Learning Technology Group v. CommissionerUnited States Tax Court · 1991
- Langer v. CommissionerUnited States Tax Court · 1990
- American Business Service Corp. v. CommissionerUnited States Tax Court · 1989
- Texas Learning Technology Group v. CommissionerUnited States Tax Court · 1991