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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.