120 T.C. No. 15
UNITED STATES TAX COURT
MEDICAL EMERGENCY CARE ASSOCIATES, S.C., AN ILLINOIS CORPORATION,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8259-01. Filed May 19, 2003.
P was a medical service corporation that provided
emergency medical services to hospitals. P contracted
with physicians to staff hospital emergency rooms. P
treated those physicians as independent contractors. P
failed to timely file required Forms 1096 and 1099, for
1996. P delinquently filed those forms on a basis
consistent with its treatment of the physicians as
independent contractors.
R determined that the physicians were employees,
and that P was not eligible for relief under sec. 530
of the Revenue Act of 1978, Pub. L. 95-600, 92 Stat.
2885, as amended (sec. 530). R determined that P did
not meet the filing requirement of sec. 530(a)(1)(B).
R’s interpretation of sec. 530(a)(1)(B) requires that a
taxpayer timely file all required returns in order to
be eligible for sec. 530 relief.
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