Jacobs v. Commissioner
United States Tax Court
P worked exclusively for B corporation, L corporation, and another related corporation. P was the president, director, and sole shareholder of B and L. P received compensation from B and L and deducted amounts for Keogh contributions. Held: P was an employee of B and L, not an independent contractor, so he could not make deductible Keogh contributions.
1Opinion of the Court
PETER H. JACOBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jacobs v. Commissioner
Docket No. 22542-91
United States Tax Court
T.C. Memo 1993-570; 1993 Tax Ct. Memo LEXIS 581; 66 T.C.M. (CCH) 1470; 17 Employee Benefits Cas. (BNA) 2225;
December 2, 1993, Filed
Decision will be entered for respondent as to the deficiencies and addition to tax under section 6661, and for petitioner as to the remaining additions to tax.
P worked exclusively for B corporation, L corporation, and another related corporation. P was the president, director, and sole shareholder of B and L. P received…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Humes v. United StatesSupreme Court of the United States · 1928
- Bemis Bro. Bag Co. v. United StatesSupreme Court of the United States · 1933
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