§1607

12 cases·12 cited

Statute text not available for this section.

12 Citing Cases

(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of “employee” then in effect appears to have - 14 - contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals’ statements concerning common law rules “may no longer be relevant.” Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, re

Mike J. Graham Trucking, Inc., Petitioner T.C. Memo. 2003-49 · 2003

31.3306(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of “employee” then in effect appears to have contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals’ statements concerning common law rules “may no longer be relevant.” Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, re

Superior Proside, Inc., Petitioner T.C. Memo. 2003-50 · 2003

(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of "employee" then in effect appears to have - 13 - contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals' statements concerning common law rules "may no longer be relevant." Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, re

Nu-Look Design, Inc., Petitioner T.C. Memo. 2003-52 · 2003

31.3306(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of “employee” then in effect appears to have contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals’ statements concerning common law rules “may no longer be relevant.” Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, r

Water-Pure Systems, Inc., Petitioner T.C. Memo. 2003-53 · 2003

(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of “employee” then in effect appears to have - 13 - contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals’ statements concerning common law rules “may no longer be relevant.” Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, re

31.3306(i)-1(e), Employment Tax Regs., were promulgated after those years and that the FUTA definition of “employee” then in effect appears to have contemplated a corporate officer who could be an independent contractor under common law, see, e.g., sec. 1607(i), I.R.C. 1939, the Court of Appeals’ statements concerning common law rules “may no longer be relevant.” Joseph M. Grey Pub. Accountant, P.C. v. Commissioner, supra at 128 n.4. The opinion in Tex. Carbonate Co. v. Phinney, supra at 291, re

1607(a); Doyon, Ltd. v. United States, supra at 1311. Essentially, ANCSA ended Federal supervision over Indian affairs and revoked the Indian reservation system in Alaska.9 43 U.S.C. 9 Only one Indian reservation, the Annette Island Reserve, remains in Alaska after the enactment of ANCSA. 43 U.S.C. sec. (continued...) - 10 - sec. 1618(a); see

le that such term includes corporate officers, appears to have contemplated that a corporate officer could be an independent contractor under the common law, in which case the officer would not be treated as an employee for FUTA purposes. See, e.g., sec. 1607(i), I.R.C. 1939. In light of the regulatory and statutory developments that occurred after the years at issue in Tex. Carbonate Co. v. Phinney, 307 F.2d at 291-292, the Court of Appeals' conclusion therein that "the usual employer-employee

le that such term includes corporate officers, appears to have contemplated that a corporate officer could be an independent contractor under the common law, in which case the officer would not be treated as an employee for FUTA purposes. See, e.g., sec. 1607(i), I.R.C. 1939. In light of the regulatory and statutory developments that occurred after the years at issue in Tex. Carbonate Co. v. Phinney, 307 F.2d at 291-292, the Court of Appeals’ conclusion therein that “the usual employer-employee

1607(a); Doyon, Ltd. v. United States, supra at 1311. Essentially, ANCSA ended Federal supervision over Indian affairs and revoked the Indian reservation system in Alaska. 43 U.S.C. sec. 1618(a); see Alaska v. Native Vill., 522 U.S. 520, 523 (1998). The ANCSA corporations received title to the land in fee simple without any Federal restriction

Paul v. Commissioner 77 T.C. 755 · 1981