- 18 -
(notice) to petitioner. In that notice, respondent determined,
inter alia, that the section 274(n)(1) limitation applied to the
per diem amounts that TLC paid to its driver-employees.
Respondent sent a notice to each of the following trucking
company clients of TLC in which respondent determined that each
such trucking company client had a deficiency in Federal income
tax (tax) for one or more taxable years22 arising out of such
trucking company client’s failure to take into account the
section 274(n)(1) limitation23 and with respect to which each
such trucking company client commenced proceedings in the Court,
as follows:
Trucking Company Client Case at Docket No.
John and Kimberly Kohler 1026-01
(NBS Trucking)
Joseph and Barbara Hix 1062-01
(Joe Hix Trucking)
Blachowske Truck Line, Inc. 1107-01
Jones Brothers Trucking, Inc. 1149-01
Lake State Transport, Inc. 1286-01
Schak Trucking Inc. 1287-01
Donald Fiereck and Beverly 1346-01
Beumer-Fiereck (Parkway Auto
Transport)
Respondent conceded the above-referenced cases. The Court
22The record did not disclose the taxable year(s) to which
the respective notices issued to certain of TLC’s trucking
company clients pertained.
23In the instant case, the 80-percent limitation applies to
taxable years ended Aug. 31, 1993, and Aug. 31, 1994, and the 50-
percent limitation applies to taxable years ended on or after
Aug. 31, 1995.
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