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10.09.2019

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. Peno Trucking Inc. v. Commissioner Internal Revenue record as providing the necessary support for each of the Tax

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For the foregoing reasons, we reverse the decision of the Tax Court. . . With the burden shifted, the Commissioner has not demonstrated that Peno Trucking does not qualify for tax relief under § 530. See McClellan, 900 F. Supp. at 107 (“ Once the taxpayer has made this prima facie showing, the burden then shifts to the . In applying the reasonable basis requirement, the Tax Court concluded that reliance on the decisions of the BWC and the OIC could not be considered reasonable. In reaching this conclusion, the Tax Court cited Nu-Look Design, for the proposition . We believe that Peno Trucking has clearly established a prima facie case that it was reasonable not to treat the truckers in question as employees, thus shifting the burden of proof to the Commissioner for the purposes of our § 530 analysis. . In the instant case, Peno Trucking argues that it has satisfied the requirements of § 530’s safe harbor provision. As evidence of this claim, Peno Trucking notes that the Tax Court concluded that “[Peno Trucking] never treated the drivers . IV. Despite the foregoing conclusions, Peno Trucking can still avoid liability under the safe harbor provisions of § 530 of the Revenue Act of 1978. . Therefore, based on the factual and credibility determinations of the Tax Court, we conclude that the truckers in question were employees of Peno Trucking. . We therefore conclude that the Tax Court did not clearly err in finding that this factor indicated the existence of an employer- employee relationship. . In its brief, Peno Trucking concedes that this factor supports a finding of an employer- employee relationship. . e. Because of the Tax Court’s credibility determination, this factor also supports a finding that an employer- employee relationship existed. . e therefore conclude that the Tax Court did not clearly err in determining that this factor also indicates the existence of an employer-employee relationship. . As a result, this factor also supports the existence of an employer-employee relationship. . incurred en route to picking up a load for hauling. The Tax Court noted these facts, but nonetheless concluded “[t]he relatively minor investment by the drivers and the substantial investment by petitioner support an employer-employee relationship.” . .” This representation by Peno Trucking to Ohio Transport gives strong indication that Peno Trucking did in fact control the truckers in question . percentages of income from the hauled freight. It would appear that the truckers negotiated the rate with Peno Trucking; in this way, Peno Trucking does appear to have controlled, to some degree, the income of the truckers. . The mere fact that the workers set their own hours and determined when to take breaks did not make them independent contractors.” . er each of these seven factors in turn as they apply to the instant case. . A provide some additional guidance as to the definition of an employer-employee relationship: . record d[id] not indicate that the BWC, the OIC, or the court of common pleas evaluated the employment relationships of petitioner’s former drivers, Chatfield and Jamison, through a common law analysis” and (2) “nothing in the record indicates the . The Tax Court found in favor of the Commissioner, concluding that the relevant factors indicated the truckers in question were employees and not independent contractors. Furthermore, the Tax Court found that Peno Trucking could not have reasonably relie . e Tax Court further explained the details of the relationship between Peno Trucking and the drivers as follows . ll . w . Th . fo . Tax Court further explained the details of the relationship between Peno Trucking and the . which explicitly provided that the drivers were independent contractors and not employees. The agreement stated, in part, as follows: . acts regarding Peno Trucking’s business operations as follow

Peno Trucking Inc. v. Commissioner Internal Revenue – CourtListener.com

r. 2004) . Brewer Qlty Homes v. CIR, 03-61040 (5th Cir. 2004) . We therefore AFFIRM the decision of the Tax Court for the reasons cited in its memorandum opinion. AFFIRMED. . us, under the clearly erroneous standard, the Tax Court’s decision in redetermining Mr. Brewer’s reasonable compensation was proper. . In fact, the Tax Court specifically states: “In determining the maximum reasonable compensation for [Mr. Brewer]’s services for the years in issue, we have considered the relevant factors listed in Owensby & Kritikos, Inc. v. Commissioner. . Similarly, Mr. Brewer clearly held a position of unmatched control and influence over the business decisions at BQH. Furthermore, because BQH admittedly did not have any type of written compensation policy, it becomes hard to argue, as BQH does, th . disparity between the salary paid Mr. Brewer and the next highest- paid employee supports a low compensation amount. . Tax Court expressed concern that because Mr. Brewer essentially controlled BQH, he was able to set his own compensation. . higher than those executives in comparable companies . The Tax Court determined that Mr. Brewer received compensation . The Tax Court was troubled by the fact that the profitability of BQH was considerably higher in 1995 and 1996 than previous years, yet BQH did not make any distributions whatsoever. . By paying compensation to Mr. Brewer in the amounts BQH did in 1995 and 1996, the Tax Court concluded that this factor weighed heavily in favor of a low compensation for Mr. Brewer. . . and as such found this factor favored a relatively high compensation. . Nonetheless, the Tax Court determined that Mr. Brewer’s compensation percentages were substantially higher than the figures urged by BQH’s expert, thus leading the Tax Court to conclude that reasonable compensati . In sum, the Tax Court made a determination that this factor favored a higher compensation for Mr. Brewer.

09.09.2019

a high compensation for Mr. Brewer . the Tax Court concluded that this factor weighed in favor of . As such, the Tax Court concluded that this factor weighed in favor of 5 BQH appears to want this panel to determine that the Tax Court did not apply the appropriate factors so that we will conduct a de novo review of the case, instead of . In fact, BQH only raises arguments as to two of the factors in the nine- factor inquiry: (1) dividend practices and return on equity; and (2) the prevailing rates of compensation for comparable positions 8 in . BQH specifically argues that although the Tax Court considered ten “indicia” of reasonable compensation, with five in favor of BQH and five in favor of the IRS, those “indicia” can only be roughly related to the nine factors the Tax . These factors include the employee’s qualifications; the nature, extent and scope of the employee’s work; the size and complexities of the business; a comparison of salaries paid with gross income and net income; the preva . The Tax Court’s reasonableness inquiry is governed by the nine-factor test set forth in Owensby & Kritikos . Here, there is no dispute that Mr. Brewer actually performed services for BQH. . Section 162(a)(1) of the Internal Revenue Code permits a corporation to deduct “a reasonable allowance for salaries or other compensation for personal services actually rendered.” 26 U.S.C. § 162(a)(1). It follows, therefore, that “the t . A finding is “clearly erroneous” when although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been co . The Tax Court’s determination of whether compensation paid by a corporation is reasonable is a question of fact that will not be reversed unless it is clearly erroneous. . come tax returns filed for fiscal years 1995 and 1996. BQH sought a redetermination of the deficiencies with the United States Tax Court.

Brewer Qlty Homes v. CIR – CourtListener.com

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Europe was being kept on the boil by rivalries between the French and Spanish kingdoms, mostly over Italian claims; and, against the advice of his older councillors, Henry in 1512 joined his father-in-law, Ferdinand II of Aragon, against France and ostens . who presided over the beginnings of the English Renaissance and the English Reformation.

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Henry VII | Biography & Facts | Britannica.com

e . The period witnessed the high point of the English Renaissance. During Elizabeth’s reign, too, through a generation of wars, Spain and the Irish rebels were beaten, the independence of France and of the Dutch was secure, and the unity of England was ass . which, after turns and trials, culminated in the establishment of the Anglican church under Elizabeth I. . beginning of the English Reformation,

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Field of the Cloth of Gold, which resulted in the betrothal of Henry VIII’s daughter, Mary, to the dauphin of Franc . England’s treaty with Spain earned the country revenue and resulted in the marriage between Catherine of Aragon and the later King Henry VIII. . Spain prospered from multiple explorations and the accumulation of resources from the New World.Like the Yorkist kings, he made use of a large council, presided over by himself, in which lawyers, clerics, and lesser gentry were active members. Sitting as the Court of Star Chamber, the council dealt with judicial matters, but less than was formerly t . To increase his income from customs dues, Henry tried to encourage exports, protect home industries, help English shipping by the time-honoured method of a navigation act to ensure that English goods were carried in English ships, and find new markets by . He had used his diplomacy not only to safeguard the dynasty but to enrich his country, using every opportunity to promote English trade by making commercial treaties. He made his country so prosperous and powerful that he was able to betroth his daughter . Spain had recently sprung into the first rank of European powers, so a marriage alliance with Spain enhanced the prestige of the Tudor dynasty, and the fact that in 1501 the Spanish monarchs allowed the marriage to take place is a tribute to the growing . The economic importance of England for the Netherlands enabled Henry to induce Maximilian and the Netherlands to abandon the pretender in 1496 and to conclude a treaty of peace and freer trade (the Intercursus Magnus).

Henry VII - Foreign policy | Britannica.com

for printing books, building more chapels and monasteries, helping reorganize Parliament, and establishing trading relations with the Netherlands and Spain. . For example, Henry managed to unite the feuding houses in England through his popular marriage to Elizabeth of York, who was viewed as having a strong claim to the throne in her own right
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