Oliver K. Robinson and Deborah L. Robinson, et al. - Page 23




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         dedicated significant time to running the company; and (4) they              
         reported only small amounts of income from other sources.  On                
         these bases, respondent asserts that the Robinsons were carrying             
         on a trade or business.                                                      
              The fact that an individual did not receive remuneration in             
         the form of wages or that the individual reported self-employment            
         income (or other remuneration besides wages) on a Schedule C does            
         not prevent the individual from being classified as an employee.             
         Pariani v. Commissioner, T.C. Memo. 1997-427; Jacobs v.                      
         Commissioner, T.C. Memo. 1993-570.  In addition, many of the                 
         facts upon which respondent relies in this case for the                      
         determination that Mr. and/or Mrs. Robinson were engaged in an               
         independent trade or business also support the Robinsons’                    
         argument that each of them, as an officer or common law employee,            
         provided significant services that were integral to the operation            
         of the company.                                                              
              Mr. Robinson was an officer of the corporation and its sole             
         shareholder in 1992 and 1993.  He provided substantial services              
         to the corporation in his capacity as an officer.  Because of his            
         expertise as a certified aircraft mechanic and pilot, he was                 
         involved in overseeing the day-to-day operation of the aircraft              
         brokerage segment of Career’s business.  He was personally                   
         involved in the inspection, negotiation, and purchase of used                
         aircraft and parts.  He traveled extensively for this part of the            






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