On June 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Santos v. Commissioner (T.C. Memo. 2020-88). The sole issue before the court in Santos v. Commissioner was whether the individuals listed on the notice of determination should be legally classified as employees (IRS’s position) or as independent contractors (petitioner’s position). The Entrepreneurial Housekeeper in Santos v. Commissioner The petitioner was born and raised in Brazil and moved to the U.S. in 1996. Shortly thereafter, she began cleaning residential homes. It turned out that the petitioner had the knack for bringing beauty out of the dingiest homes, and soon the word got around, and she began cleaning apartments and later the apartment buildings themselves. The petitioner could not do this alone, and so she recruited other Brazilian immigrants to assist her through advertisements she posted in Brazilian hair salons. Can’t fault the lady for knowing her…