On August 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114). The primary issue before the court in Reflectxion Resources Inc. v. Commissioner was whether the Tax Court has jurisdiction to determine whether the petitioner was entitled to relief from worker classification liabilities pursuant to § 530 of the Revenue Act of 1978. Background to Reflectxion Resources Inc. v. Commissioner The petitioner was as a medical staffing agency during 16 quarters (at least) from 2008 through 2011 (the periods at issue). It employed various therapists to fulfill contracts with healthcare facilities, who sought therapists for temporary staffing and for direct hire purposes. Though the petitioner operated throughout the country, they hired local therapists for the client. The petitioner also has “travel” shrinks, some of whom were reimburse correctly (and withheld) for travel expenses, but others were reimbursed with the…