HI-Q Personnel, Inc. v. Commissioner

132 T.C. No. 13

UNITED STATES TAX COURT HI-Q PERSONNEL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22101-04. Filed May 4, 2009. P corporation provided skilled and unskilled laborers for casual employment (temporary laborers) to more than 250 client companies. P gave temporary laborers the option of being paid by check or in cash. For those paid in cash, P failed to withhold Federal income taxes and pay either the employer or employee portions of FICA taxes (together, employment taxes) for all taxable quarters in 1995, 1996, 1997, and 1998. In 2002, P’s…