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053827P.pdf   08/23/2006  Transport Labor  v.  CIR
   U.S. Court of Appeals Case No:  05-3827
   Agency   
   [PUBLISHED] [Loken, Author, with John R. Gibson, and Colloton, Circuit
   Judges]
Federal Tax. Taxpayer, a Professional Employer Organization providing payroll and other services to trucking companies, was not subject to the deduction limitation set out in 26 U.S.C. Sec. 274(n)(1)(A), and the tax court erred in applying the limitation; case remanded for a redetermination of the taxpayer's deficiencies.