Medical Emergency Care Associates, S.C., An Illinois Corporation - Page 1

                                   120 T.C. No. 15                                    

                               UNITED STATES TAX COURT                                

                                    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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