Ron Lykins, Inc. - Page 9

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          presumption.  They show that those who worked at Lykins Financial           
          continued to receive paychecks drawn on Lykins Inc., continued to           
          receive benefits provided by Lykins Inc., and continued to have             
          their Social Security tax paid for by Lykins Inc.  They had                 
          worked at Lykins Inc. at the start of 2000, and those working on            
          financial services during the year were told to do so by Lykins             
          Inc.  Lykins Financial even reimbursed Lykins Inc. for their                
          wages, taking a deduction; Lykins Inc. reported those                       
          reimbursements as income.                                                   
               Simply allocating the costs of Lykins Inc. employees to                
          Lykins Financial does not make them Lykins Financial employees.             
          And, while the line between Lykins Inc. and Lykins Financial was            
          clear only in its blurriness, we conclude on the peculiar facts             
          of this case--especially the fact that before Lykins Financial              
          was formed, all these employees were Lykins Inc. employees, and             
          continued to have their wages, benefits, and taxes paid by Lykins           
          Inc.--that they continued to be Lykins Inc. employees throughout            
          the year.                                                                   
               This makes deciding the case easy.  Lykins Inc. and the                
          Commissioner stipulated to a breakdown of Lykins Inc.’s                     
          employees’ hours into two categories:  hours spent on accounting            
          and consulting services, and hours spent on investment services.            
          The exhibit shows that 80.53 percent of employee hours in 2000              
          were spent on accounting services, while 19.47 percent of                   






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