Legal Opinion

Hi-Q Pers., Inc. v. Comm'r

United States Tax Court

Decided May 4, 2009No. 22101-04Published

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.

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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 president and sole shareholder, N, pleaded guilty to failing to withhold and pay the employment taxes and to conspiracy to defraud the United States. R determined P was…

1Opinion of the Court

HI-Q PERSONNEL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hi-Q Pers., Inc. v. Comm'r

No. 22101-04

United States Tax Court

132 T.C. 279; 2009 U.S. Tax Ct. LEXIS 12; 132 T.C. No. 13;

May 4, 2009, Filed

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…

2Cases cited27 opinions

  1. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Standefer v. United StatesSupreme Court of the United States · 1980
  4. Jean Alexander Cosmetics, Inc. v. L'OreaL Usa, Inc. Redkin 5th Avenue, N.Y.CCourt of Appeals for the Third Circuit · 2006
  5. Otte v. United StatesSupreme Court of the United States · 1974

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