Marjorie Cathey Miller v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
1Opinion of the Court
TASHIMA, Circuit Judge.
Marjorie Cathey Miller appeals a decision of the United States Tax Court, granting summary judgment in favor of the Commissioner of Internal Revenue. Miller contends that the tax court erred in concluding that she was not entitled to an abatement of interest on employment taxes under 26 U.S.C. § 6404(e). We affirm.
BACKGROUND
In 1984, 1985, and 1986, Miller operated a beauty salon in the State of Washington. Miller leased out individual spaces in the salon to individual beauticians and treated the lessees as independent contractors rather than employees for tax purposes.…
2Cases cited19 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Heckler v. ChaneySupreme Court of the United States · 1985
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Woodral v. CommissionerUnited States Tax Court · 1999
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- Hinck v. United StatesUnited States Court of Federal Claims · 2005
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