Most likely it does, but it is possible that Terry has a reasonable basis for the decision.
The first is if the employer had no reasonable basis for treating the worker as an independent contractor for tax purposes.
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Such issues seldom are raised because the employer nearly always has a reasonable basis for treating a worker as an independent contractor.
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Since DOMA has been declared unconstitutional and the Justice Department has declared it indefensible, there is a reasonable basis for that position.
Under the old standard, tax pros could safely recommend positions (on routine issues, not tax shelters) that had a "realistic possibility" of success--meaning, what the heck, if there's some reasonable basis, go for it.
On the accuracy penalty, once the IRS shows that it hits the tax understatement hits the threshold, it is up to the taxpayer to show that he had a reasonable basis for his filing position.
Where an employer has consistently treated workers as independent contractors for employment tax purposes, and there has been a reasonable basis for such treatment, then, under Section 530 of the Revenue Act of 1978, reclassification of the workers as employees for purposes of federal employment taxes shall only have prospective effect.
Therefore, by way of example and for purposes of the analysis, this memorandum assumes that after a good faith investigation, the lawyer advising the financial institution desiring to enter the lucrative SCF industry will determine that there is a reasonable basis to conclude that a consensus exists among Shariah authorities on the fundamental purpose and methodologies of Shariah: The purpose is submission.
Rule 2111 is composed of three main obligations: reasonable-basis suitability, customer-specific suitability, and quantitative suitability.
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However, BBC business editor Robert Peston says RBS was advised that there was a reasonable legal basis for suing him for the return of some of the pension pot.
It seems a reasonable enough basis for the speculation.
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First, to what extent does existing research provide a reliable and reasonable scientific basis for the notion that breast implants filled with silicone gel cause or exacerbate chronic illnesses such as autoimmune diseases?
The panelists could throw up their hands and acquit Avandia on the basis of reasonable doubt.
Ratcheting up the time limit on a regular basis becomes a reasonable way of approximating that perpetuity.
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In his case it is probably reasonable to assume that his basis in the stock is negligible so that all his proceeds are gain.
Back in 2009 when a recommendation against routine mammograms for women age 40 to 49 came out, there was a backlash despite the fact that the basis for it was scientifically reasonable.
But the practice had kept records of the missed appointments and the advice they had given her over the years and the claim was successfully defended on the basis that doctors did all that was reasonable to persuade her to attend.
She was told the judge felt that on the basis of that evidence, it could not be proved beyond reasonable doubt that her memories were real.
While the Court ultimately concluded that there were sufficient disclosures to inform a reasonable investor, the analysis the Court used to get to that conclusion provides the basis today for the materiality analysis.
If they make that pledge, it is probably reasonable for families and local authorities to trade with Southern Cross on a business-as-usual basis.
Given that Freesat had been approved by the BBC Trust on the basis that it was a good use of income from the licence fee, it was "not reasonable to withhold information" about how much the service would cost, MPs said.
Given that medical professionals and regulators act on the basis of evidence of causation that is not statistically significant, it stands to reason that in certain cases reasonable investors would as well.
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