This case prompts learners to analyze compensation data and worker agreements to assess a company's likely compliance with requirements for classifying workers as independent contractors rather than employees based on the factors the Internal Revenue Service (IRS) uses for compliance with IRS Rev. Rul. 87-41 and Treas. Reg. § 31.3401(c)-1. Students combine tax research and data analysis to identify risky employment practices, recommend corrective action to bring the company into compliance, and estimate potential penalties if the IRS were to declare the company not in compliance. Students complete a data analysis report as a basis for preparing a research memorandum. Students electing tax practice will need to be able to perform similar analyses of client data in advance of IRS audits given that the IRS analyzes accounting data when auditing taxpayers. Given the guidance in the Teaching Notes, no database query experience is necessary on the part of instructors.

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