Employee Benefit Program: Circuit court overrules IRS’s attempt to deny taxpayers deduction

Here is court case. A husband and his wife operate a farm. The husband is the owner and the decision maker on the farm. Before 2001, the wife worked for her husband on the farm for 20 years without compensation. In 2001, the wife becomes an employee of the farm supervised by the husband. The wife worked about 40 hours a week. She set up an employee medical reimbursement plan. The couple used the plan to deduct 100 percent of their federal, state and FICA taxes for family medical costs and saved on average of $4000 a year. The wife opened an individual checking account and used it to pay family insurance premiums and medical bills not covered by insurance for the couple and their two children. Besides reimbursing her for these expenses, the husband paid his wife $100 per month in wages. On Form 1040 for 2001 and subsequent years, the wife’s occupation was specified as “Housewife.”
The couple tried to fully comply with the employment and tax rules involved when a self-employed individual hires a spouse. The wife followed the rules of the plan, she kept a log of her hours spent on farm work,. The couple kept tax records, they deduct and report payroll taxes and issue w-2’s Every year, the wife provide her Third Party Administrator (“TPA) with the detailed of medical expenses claimed. The TPA in return provided her a report indicating the total allowable benefit amount, which the couple then reported as a business expenses deduction on their tax return.
The Internal Revenue Service (“IRS”) conducted audit looking at the years 2001 and 2002. During these years the couple’s medical deductions saved them approximately $4000 and $7000 respectively. The IRS agent disallowed the deductions because they were established on the name of the husband and not on the name of the employee, the wife. The IRS built their case on the assertion that the wife was not a bona fide employee of her husband. As proof, the IRS cited that before 2001 the wife worked for her husband on the farm for 20 years without compensation and on the form 1040 of the years in questions the wife was listed as “Housewife.”
The Tax Court sided with the IRS and the couple appealed to the Tenth Circuit Court. The Tenth Circuit remanded with instruction to determine if the wife was an employee. The Ten Circuit required the tax court to examine the issue again based on the common law tests to determine if the wife was not the husband’s employee. The court also dismissed the argument that funds for medical reimbursement must be paid from separate account and the fact she owned half of the joined account did not withstand scrutiny. Lastly, the Tenth circuit court emphasized that no minimum wage must be paid in these situations and that there was nothing wrong with compensation combination of small cash wages and large fringe benefits. One important factor that helped the couple win this case was the fact that they followed the Medical Reimbursement Program’s instructions very carefully and closely.


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