Tax File Memorandum
Mary Robinson licensed surveyor of Silver Corporation Relevant Facts Silver Corporation, a calendar year C corporation, is solely owned by Mary Robinson. Silver Corporation is a surveying company that has been in business since its incorporation in 2012. Mary, the only employee, is a licensed surveyor. However, she is not a licensed engineer. Silver Corporation meets the requirements for a Personal Service Corporation. Silver Corporation’s 2012 and 2013 tax returns were audited by the IRS. The IRS assessed tax deficiencies stemming from its conclusion that the corporation was a personal service corporation that is subjected to the flat ...
