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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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