Specialty Transport & Delivery Services, Inc. - Page 4




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          pickup and delivery services for clients on behalf of petitioner.           
          No other person provided any services to petitioner.                        
               During the period in issue, petitioner received client                 
          referrals from Pyle Transport Services, Inc. (Pyle Transport), of           
          West Chester, Pennsylvania.  Ludlow performed services on behalf            
          of petitioner pursuant to an “Independent Contractor Service                
          Agreement” between petitioner and Pyle Transport, dated March 25,           
          1993, and identifying Ludlow as the driver for petitioner.                  
               During 1996, 1997, and 1998, petitioner maintained a                   
          business/commercial checking account.  Ludlow shared signature              
          authority on petitioner’s account with his spouse.  Petitioner              
          did not make regular payments at fixed times to Ludlow for his              
          services.  Rather, Ludlow, or his wife, obtained funds from                 
          petitioner’s bank account to pay Ludlow as his needs arose.                 
          Petitioner neither classified any payment as a dividend nor                 
          distributed any dividends to shareholders from 1996 through 1998.           
          Petitioner’s Tax Reporting                                                  
               Petitioner timely filed Forms 1120S, U.S. Income Tax Return            
          for an S Corporation, and related schedules, for 1989 through               
          1995.  On these returns, petitioner did not report treating                 
          Ludlow, or any other individual, as an employee of petitioner.              
               Petitioner filed a Form 1120S for each of the years 1996,              
          1997, and 1998.  Petitioner reported ordinary income from its               
          trade or business of $15,605.36, $27,362.14, and $38,486.89 for             






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Last modified: May 25, 2011