Employee Retention Credit Does Not Apply to Wages of Owner and Family

(Parker Tax Publishing August 2021)

In updated guidance on the employee retention credit (ERC), the IRS responds to a number of questions about the credit which it has received from practitioners and taxpayers. Significantly, as a result of the constructive ownership rules of Code Sec. 267, the IRS states that wages paid to majority owners, their spouses, and kids generally are not qualified wages for purposes of the ERC. Notice 2021-49.

Background

Section 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as originally enacted in 2020, provides for an employee retention credit (ERC) for eligible employers, including tax-exempt organizations, that pay qualified wages, including certain health plan expenses, to some or all employees after March 12, 2020, and before January 1, 2021. Section 206 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act) further amended Section 2301 for qualified wages paid after March 12, 2020, and before January 1, 2021, primarily expanding eligibility for certain employers to claim the credit. Section 207 of the Relief Act further amended Section 2301 to extend the application of the ERC to qualified wages paid after December 31, 2020, and before July 1, 2021, and to modify the calculation of the credit amount for qualified wages paid during that time. Section 9651 of the American Rescue Plan Act of 2021 (ARP) enacted Code Sec. 3134(n) to provide an ERC for wages paid after June 30, 2021, and before January 1, 2022. Under the ARP, the credit for the last two quarters of 2021 is taken against an employer's Medicare tax as opposed to a credit against the employer's social security tax as is the case for 2020 and the first two quarters of 2021.

In March, the IRS issued Notice 2021-20, providing guidance on the ERC under Section 2301 of the CARES Act, as amended by Section 206 of the Relief Act. Notice 2021-20 applies for calendar quarters in 2020. In April, the IRS issued Notice 2021-23, which describes the extension of the ERC for qualified wages paid by an eligible employer after December 31, 2020, and before July 1, 2021.

On August 6, the IRS issued Notice 2021-49, which supplements the guidance in Notice 2021-20 and Notice 2021-23 and is applicable for ERCs calculated under Code Sec. 3134(n) on qualified wages paid for the third and fourth quarters of 2021.

In Notice 2021-49, the IRS (1) addresses the impact that the constructive ownership rules have on determining whether wages paid to majority owners and their spouses may be treated as qualified wages for the purposes of the ERC; (2) reviews the definition of a full-time employee and whether that definition includes full-time equivalents (FTEs); (3) classifies tips as qualified wages and discusses the interaction of the ERC and the Code Sec. 45B credit; (4) discusses the qualified wages deduction disallowance rule and the impact of that rule on employers who filed amended employment tax returns claiming the ERC after filing their business income tax returns on which they took wage deductions; (5) expands the definition of an "eligible employer" to include a recovery startup business; (6) modifies the definition of qualified wages for severely financially distressed employers; and (7) provides that the ERC does not apply to qualified wages taken into account as payroll costs in connection with a shuttered venue grant under Section 324 of the Economic Aid to Hard-Hit Small Businesses, Non-Profits, and Venues Act, or a restaurant revitalization grant under Section 5003 of the ARP.

Exclusion of Owner and Family Wages from ERC Calculation

The ERC only applies to "qualified wages." One of the most surprising aspects of Notice 2021-49 is the negative impact that the constructive ownership rules have on determining whether small family-owned businesses have qualified wages with respect to amounts paid to family members. Under Notice 2021-49, qualified wages do not include wages paid to a majority owner who basically has any living relatives. This would appear to be at odds with the legislative intent behind the enactment of the ERC but it does follow the technical language of the ERC provisions. Section 2301(e) of the CARES Act and Code Sec. 3134(e) provide, in relevant part, that rules similar to the rules of Code Sec. 51(i)(1) (i.e., the work opportunity credit (WOC) rules) apply in calculating qualified wages. Code Sec. 51(i)(1) generally provides that wages paid to certain related individuals are not taken into account for purposes of the WOC. Specifically, Code Sec. 51(i)(1) and Reg. Sec. 1.51-1(e)(1) provide that wages are not taken into account with respect to an individual who bears any of the relationships described in Code Sec. 152(d)(2)(A)-(H) to the following (1) the taxpayer, or (2) if the taxpayer is a corporation, to an individual who owns, directly or indirectly more than 50 percent in value of the outstanding stock of the corporation (majority owner of a corporation), or (3) if the taxpayer is an entity other than a corporation, to any individual who owns, directly or indirectly, more than 50 percent of the capital and profits interests in the entity (majority owner of a noncorporate entity).

Code Sec. 51(i)(1)(A) includes a parenthetical stating that an individual's ownership is determined under Code Sec. 267(c). In Notice 2021-49, the IRS said it has concluded that the Code Sec. 267(c) ownership attribution rules apply for purposes of determining both an individual's ownership of stock of a corporation and an individual's capital and profits interests in a partnership or other entity, consistent with the language in Reg. Sec. 1.51-1(e)(1)(iii) and Code Sec. 51(i)(1)(A).

Initially, the IRS stated, simply applying the rules of Code Sec. 152(d)(2)(A)-(H) for purposes of the ERC, before taking into consideration the attribution rules of Code Sec. 267(c), the wages paid to employees with the following relationships to a majority owner of a corporation, partnership, or other entity are not qualified wages and thus do not qualify for the ERC:

(1) A child or a descendant of a child.

(2) A brother, sister, stepbrother, or stepsister.

(3) The father or mother, or an ancestor of either.

(4) A stepfather or stepmother.

(5) A niece or nephew.

(6) An aunt or uncle.

(7) A son-in-law, daughter-in-law, father-in-law, mother-in-law, brother-in-law, or sister-in-law.

(8) An individual (other than a spouse, determined without regard to Code Sec. 7703, of the taxpayer) who, for the tax year of the taxpayer, has the same principal place of abode as the taxpayer and is a member of the taxpayer's household.

Code Sec. 267(c) provides rules regarding the constructive ownership of stock for purposes of determining whether an individual is considered a majority owner of a corporation. It sets forth the following rules to determine whether an individual has constructive ownership of stock of a corporation:

(1) stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust is considered as being owned proportionately by or for its shareholders, partners, or beneficiaries;

(2) an individual is considered to own the stock owned, directly or indirectly, by or for the individual's family;

(3) an individual owning (otherwise than by the application of (2)) any stock in a corporation is considered to own the stock owned, directly or indirectly, by or for his partner;

(4) the family of an individual includes only his brothers and sisters (whether by the whole or half-blood), spouse, ancestors, and lineal descendants; and

(5) stock constructively owned by a person by reason of the application of (1) will be treated, for the purpose of applying (1), (2), or (3), as actually owned by that person. Stock constructively owned by an individual by reason of the application of (2) or (3) will not be treated as owned by the individual to again apply either rule to reattribute and make another individual the constructive owner of the stock.

Observation: The above discussion is limited to a majority owner of a corporation because a partner in a partnership, or other noncorporate entity, generally cannot be an employee of that entity, and therefore cannot be paid wages within the meaning of Code Sec. 3121(a). A partner or other self-employed individual is not eligible for the ERC on the individual's earned income.

Applying the rules of Code Sec. 152(d)(2)(A)-(H) and Code Sec. 267(c), a majority owner of a corporation is a related individual for purposes of the ERC, and such owner's wages are not qualified wages, if that owner has a brother or sister (whether by whole or half-blood), ancestor, or lineal descendant. Further, the spouse of a majority owner is a related individual for purposes of the ERC, whose wages are not qualified wages, if the majority owner has a family member who is a brother or sister (whether by whole or half-blood), ancestor, or lineal descendant (and thus is deemed to own the majority owner's shares under Code Sec. 267(c)) and the spouse bears a relationship described in Code Sec. 152(d)(2)(A)-(H). For example, a direct majority owner's brother would be a constructive majority owner under Code Sec. 267(c)(2) and (4) and the spouse of the direct majority owner would be considered a related individual to the constructive majority owner by virtue of the in-law relationship described in Code Sec. 152(d)(2)(G).

In the event that the majority owner of a corporation has no brother or sister (whether by whole or half-blood), ancestor, or lineal descendant as defined in Code Sec. 267(c)(4), then neither the majority owner nor the spouse is a related individual within the meaning of Code Sec. 51(i)(1) and the wages paid to the majority owner and/or the spouse are qualified wages for purposes of the ERC, assuming the other requirements are satisfied. Notice 2021-49 includes numerous examples of how these rules work in deciding if a business has qualified wages.

Example: ABC Corporation is owned 80 percent by Ellen and 20 percent by Frank, Ellen's son. ABC is an eligible employer with respect to the first calendar quarter of 2021. Both Ellen and Frank are employees of ABC. Pursuant to the attribution rules of Code Sec. 267(c), both Ellen and Frank are treated as 100 percent owners of ABC. Accordingly, ABC may not treat as qualified wages any wages paid to either Ellen or Frank because they are each related individuals for purposes of the ERC.

Example: DEF is an S corporation and is owned 100 percent by John. DEF is an eligible employer with respect to the first calendar quarter of 2021. John is married to Karen, and they have no other family members (i.e., no living parents, siblings, children, etc.) as defined in Code Sec. 267(c)(4). John and Karen are both employees of DEF. Pursuant to the attribution rules of Code Sec. 267(c), Karen is attributed 100 percent ownership of DEF, and both John and Karen are treated as 100 percent owners. However, John and Karen do not have any of the relationships to each other described in Code Sec. 152(d)(2)(A)-(H) (i.e., because neither has any relatives). Accordingly, wages paid by DEF to John and Karen in the first calendar quarter of 2021 may be treated as qualified wages for purposes of the ERC if the amounts satisfy the other requirements to be treated as qualified wages.

Observation: A 50-50 ownership of a business with unrelated parties will not run afoul of these constructive ownership rules as long as no attribution rules apply to attribute ownership to the other party.

Practice Tip: It appears that the rule regarding majority owners not being eligible for the ERC runs contrary to the intent of the ERC legislation. It's realistic to assume that Congress will try to fix this in the near future. For returns already filed, the IRS could assess penalties for ERCs taken by majority owners and spouses where, in light of the discussion above, they were not entitled to such credits. It would certainly be rational for those owners to assert reasonable cause for taking the position that they were entitled to the ERC based on their reliance on a tax practitioners (where in fact they did so) and the fact that no IRS guidance up until Notice 2021-49 had indicated this would be an issue. Additionally, for returns that have already been filed, under the Supreme Court's decision in Badaracco v. Comm'r, 464 U.S. 386 (1984), taxpayers have no statutory obligation to file an amended return. However, Circular 230 provides that tax advisors have an obligation to advise clients to file an amended return when there is an error or omission on a return. Going forward, majority owners who forgo the credit based on the IRS's interpretation will have three years from when an employment tax return is due to file an amended return and claim the ERC, assuming the law is fixed. On the other hand, such owners could also go ahead and claim the credit under the theory that this is how the law is supposed to work. In that case, they must disclose that they are taking a filing position adverse to Notice 2021-49. If they end up being wrong and the law is not subsequently changed, then those owners will be subject to penalties and interest.

Full-time Employees and Full-time Equivalents

Notice 2021-20 and Notice 2021-23 set forth the rules for determining the amount of qualified wages paid after March 12, 2020, and before January 1, 2021, and the amount of qualified wages paid after December 31, 2021, and before July 1, 2021, respectively. Under the CARES Act, the definition of "qualified wages" depends on the average number of full-time and full-time-equivalent (FTE) employees that the eligible employer had in 2019.

Observation: Solely for purposes of determining whether an employer is an applicable large employer, FTEs are treated as full-time employees. To calculate the FTEs treated as full-time employees, an employer divides the aggregate number of hours of service of employees who are not full-time employees during the month by 120.

For an eligible employer that had more than 100 such employees in 2019 (i.e., a large eligible employer), qualified wages are defined as wages paid by the eligible large employer with respect to which an employee is not providing services due to circumstances that cause the eligible employer to meet either the governmental order test or the reduced gross receipts test (i.e., two tests in the CARES Act which determine if an employer is an "eligible" employer for purposes of the ERC). While Code Sec. 3134 generally includes the same rules for determining qualified wages paid in the third and fourth calendar quarters of 2021, there are a few exceptions.

Regarding the definition of "full-time employee" for the purpose of calculating the ERC for the third and fourth quarter of 2021, Notice 2021-49 provides that such term means an employee who, with respect to any calendar month in 2019, had an average of at least 30 hours of service per week or 130 hours of service in the month. For purposes of determining whether an eligible employer is a large eligible employer or a small eligible employer, eligible employers are not required to include FTEs when determining the average number of full-time employees. Thus, only full-time employees are counted for purposes of determining if an employer is a large or small eligible employer. However, for purposes of identifying qualified wages for the ERC, an employee's status as a full-time employee is irrelevant and wages paid to an employee who is not full-time may be treated as qualified wages if all other requirements to treat the amounts as qualified wages are satisfied.

Tips Are Qualified Wages and Are Eligible for Both the ERC and Sec. 45B Credit

Notice 2021-49 provides that cash tips paid to employees are qualified wages for purposes of the ERC if the amount of the cash tips received by an employee is $20 or more in a calendar month. The notice provides that the employer is allowed to claim both the ERC and the Code Sec. 45B credit for the portion of the employer's social security taxes paid with respect to employee cash tips. Thus, the employer can claim these two credits for the same wages.

ERC, PPP Loans, and Amended Returns

Section 2301(e) of the CARES Act and Code Sec. 3134(e) provide the general rule that no deduction is allowed for the portion of wages which is equal to the ERC. Originally, employers applying for Paycheck Protection Program (PPP) loans were not allowed to take an ERC during a period covered by a PPP loan. However, that subsequently changed and employers are allowed to take the ERC for qualified wages in the year they also used PPP loan amounts to pay wages. But owners aren't allowed to take the ERC for wages paid with PPP amounts. As a result, employers who had already filed their employment tax returns under the assumption that they could not claim the ERC because they had PPP loans, filed amended employment tax returns to claim the ERC for eligible wages. While businesses can take a compensation deduction for amounts paid with PPP loans, the amount of an employer's ERC reduces the employer's compensation deduction under rules similar to Code Sec. 280C(a).

Notice 2021-49 requires those taxpayers to file amended income tax returns to reduce the compensation deduction for the amount of the ERC claimed. According to the IRS, the compensation deduction must be reduced for the year the wages were paid (and the ERC taken) and not a subsequent year.

Maximum ERC Amount; Increased ERC Provided for Recovery Startup Businesses

Notice 2021-23 provides the rules related to the maximum amount of an eligible employer's ERC for the first and second calendar quarters in 2021. The ERC equals 70 percent of qualified wages (including allocable qualified health plan expenses), and the amount of qualified wages (including allocable qualified health plan expenses) taken into account with respect to any employee is limited to $7,000 for any calendar quarter, for a maximum credit of $7,000 per employee for each of the first and second calendar quarter of 2021. Under Code Sec. 3134(a) and Code Sec. 3134(b)(1)(A), these limits continue to apply in the third and fourth calendar quarters in 2021. However, for a recovery startup business (defined below), a higher third and fourth quarter credit limit applies.

Specific rules apply for determining whether an employer is an eligible employer for purposes of the ERC for 2020 and the first two quarters of 2021. Applying the same rules as for the first two quarters of 2021, Code Sec. 3134(c)(2)(A)(ii) provides that, for the third and fourth calendar quarters of 2021, an employer may be eligible for the ERC with respect to a calendar quarter if (1) the operation of the employer's trade or business is fully or partially suspended due to orders from an appropriate governmental authority limiting commerce, travel, or group meetings (for commercial, social, religious, or other purposes) due to COVID-19, or (2) the employer experiences a decline in gross receipts. Code Sec. 3134 adds a third category of employers that are eligible for the ERC for the third and fourth calendar quarters of 2021 - recovery startup businesses.

A recovery startup business is defined in Code Sec. 3134(c)(5) as an employer (1) that began carrying on any trade or business after February 15, 2020, (2) for which the average annual gross receipts of the employer for the three-tax-year period ending with the tax year that precedes the calendar quarter for which the credit is determined does not exceed $1,000,000, and (3) that is not otherwise an eligible employer due to a full or partial suspension of operations or a decline in gross receipts. In the case of an eligible employer that is a recovery startup business, an ERC of up to $50,000 is allowed for each of the third and fourth calendar quarters.

Code Sec. 3134(c)(5) indicates that the average annual gross receipts of an employer is determined by applying rules similar to the rules in Code Sec. 448(c)(3) and the three-tax-year period ends with the tax year preceding the calendar quarter for which the employer is claiming the ERC. Notice 2021-49 states that it is appropriate for the term "qualified wages," for purposes of the ERC, to include wages paid by a recovery startup business.

Observation: According to the IRS, Congress intended to include Code Sec. 501(c) tax-exempt organizations within the three categories of an eligible recovery startup business. Thus, if such an entity meets the criteria, it is treated as a recovery startup business based on all of its operations and average annual gross receipts determined under Code Sec. 6033.

The determination of whether an employer is a recovery startup business is made separately for each calendar quarter. The aggregation rules described in Notice 2021-20 apply when determining whether an employer's trade or business is fully or partially suspended or the employer experiences a decline in gross receipts. Similarly, the aggregation rules described in Notice 2021-20 apply when determining if an employer is a recovery startup business. The aggregation rules also apply with respect to the $50,000 limitation on the credit.

Qualified Wages and Severely Financially Distressed Employers

An employer's ERC is calculated based on qualified wages paid. Notice 2021-20 and Notice 2021-23 set forth the rules for determining qualified wages paid after March 12, 2020, and before January 1, 2021, and qualified wages paid after December 31, 2021, and before July 1, 2021, respectively. Code Sec. 3134 generally includes the same rules for determining qualified wages as the rules for wages paid in the first and second calendar quarters of 2021, with a few exceptions.

In defining "qualified wages," Code Sec. 3134(c)(3)(A) provides a distinction in treatment between large eligible employers and small eligible employers (for a large eligible employer, qualified wages are limited to wages paid to an employee for time the employee is not providing services due to a full or partial suspension or decline in gross receipts). Code Sec. 3134(c)(3)(B) provides that in the case of any employer that was not in existence in 2019, Code Sec. 3134(c)(3)(A) is applied by substituting "2020" for "2019" each place it appears and requires eligible employers not in existence in 2019 to determine the average number of full-time employees in 2020 instead of 2019. Notice 2021-20 provides rules for determining the average number of full-time employees, including for employers that came into existence in 2020. Notice 2021-49 provides that the rules set forth in Notice 2021-20 for determining the average number of full-time employees continue to apply in the third and fourth calendar quarters of 2021.

Code Sec. 3134(c)(3)(C) provides a different rule for qualified wages paid by severely financially distressed employers. A severely financially distressed employer is defined as an employer that is an eligible employer based on a decline in gross receipts, but the gross receipts for the eligible employer for the calendar quarter are less than 10 percent of the gross receipts as compared to the same calendar quarter in calendar year 2019, instead of less than 80 percent. Accordingly, for the third and fourth calendar quarters of 2021, an eligible employer with gross receipts that are less than 10 percent of the gross receipts for the same calendar quarter in calendar year 2019 (or 2020, if the employer was not in existence in 2019) is a severely financially distressed employer.

Practice Tip: These rules apply for determining whether an eligible employer that has already met the decline in gross receipts test will be treated as a severely financially distressed employer with respect to qualified wages. A severely financially distressed employer is not a separate category of eligible employer. An employer should first determine whether it satisfies the definition of an "eligible employer" before determining whether it is considered a severely financially distressed employer.

If an employer is a severely financially distressed employer, the term "qualified wages" means wages paid by such employer with respect to an employee during any calendar quarter. Accordingly, for the third and fourth calendar quarters of 2021, a severely financially distressed employer that is a large eligible employer may treat all wages paid to its employees during the quarter in which the employer is considered severely financially distressed as qualified wages.

Example: ABC is a large eligible employer with gross receipts in the third quarter of 2021 equal to 15 percent of its gross receipts in the third quarter of 2019. ABC is not a severely financially distressed employer for the third quarter of 2021 based on the third quarter's gross receipts. However, ABC's gross receipts in the second quarter of 2021 are less than 10 percent of its gross receipts in the second quarter of 2019. Therefore, ABC may elect to use the alternative quarter election rule to meet the definition of a severely financially distressed employer in the third quarter of 2021. In the third quarter of 2021, ABC pays its employee, John, $10,000 in wages for services he provided during the third quarter. ABC may claim the ERC in the third quarter of 2021 (the quarter in which ABC is determined to be severely financially distressed under the alternative quarter election rule) and may treat all of the wages paid to John during the third quarter of 2021 as qualified wages. In the fourth quarter of 2021, ABC's gross receipts equal 20 percent of its gross receipts in the fourth quarter of 2019. ABC is not a severely financially distressed employer for the fourth quarter of 2021 based on the fourth quarter's gross receipts. In addition, ABC cannot use the alternative quarter election rule in the fourth quarter of 2021 to qualify as a severely distressed employer because ABC's gross receipts in the third quarter of 2021 are not less than 10 percent of its gross receipts in 2019; therefore, ABC is not a severely financially distressed employer (though it is still an eligible employer) in the fourth quarter of 2021. ABC pays John $10,000 in wages in the fourth quarter of 2021 for services he provided during the fourth quarter of 2021. ABC may not treat any of the wages paid to John for services provided during the fourth quarter as qualified wages because ABC is a large eligible employer and does not meet the definition of a severely financially distressed employer for the fourth quarter of 2021.

Code Sec. 3134(c)(3)(D) provides that for the third and fourth calendar quarters of 2021, the term "qualified wages" does not include any wages taken into account under Code Secs. 41, 45A, 45P, 45S, 51, 1396, 3131, and 3132. Thus, wages that are taken into account for purposes of those provisions cannot be taken into account for purposes of the ERC.

Coordination of the ERC with Certain Programs

Notice 2021-49 provides that the ERC does not apply to qualified wages (1) paid by an eligible employer if the qualified wages are taken into account as payroll costs in connection with a covered loan under the PPP, (2) taken into account as payroll costs in connection with a grant under Section 324 of the Economic Aid to Hard-Hit Small Businesses, Non-Profits, and Venues Act, enacted in the Consolidated Appropriations Act, 2021 (i.e., shuttered venue operators grant), or (3) taken into account as payroll costs in connection with a restaurant revitalization grant under Section 5003 of the ARP (i.e., restaurant revitalization grant).

Observation: For additional information on the interaction of the ERC with the PPP, shuttered venue operators grant, and restaurant revitalization grant, and a safe harbor that may apply with respect to the calculation of gross receipts, see the discussion of Rev. Proc. 2021-33 elsewhere in this issue of Parker's Federal Tax Bulletin.

Extension of ERC Statute of Limitations

Code Sec. 3134(l) extends the statute of limitations so that the limitation on the time period for assessing any amount attributable to the ERC will not expire before the date that is five years after the later of (1) the date on which the original return that includes the calendar quarter with respect to which the credit is determined is filed, or (2) the date on which the return is treated as filed. Notice 2021-49 provides that the extension of statute of limitations applies to the ERC claimed for the third and fourth calendar quarters of 2021 under Code Sec. 3134 but does not apply to the ERC claimed under Section 2301 of the CARES Act.

Gross Receipts Safe Harbor

Notice 2021-20 permits an employer that acquires a business in 2020 to include the gross receipts of the acquired business in its gross receipts for 2019 to determine whether the employer experienced a significant decline in gross receipts. The safe harbor allows the employer to include the gross receipts of the acquired business regardless of the fact that the employer did not own the acquired business during a calendar quarter in 2019. In response to questions of whether this rule continues to apply to employers that acquire businesses in 2021, the IRS said that yes, this rule continues to apply to employers that acquire businesses in 2021 for purposes of measuring whether a decline in gross receipts occurred.

In response to questions of how to calculate gross receipts of employers that came into existence in the middle of a calendar quarter in 2020, the IRS noted that Notice 2021-20 provides rules for determining gross receipts for an employer that came into existence in 2019. The same rules set forth in Notice 2021-20, the IRS said, continue to apply for 2021.

Example: Employer ABC came into existence in the third quarter of 2020 and used that quarter as the base period to determine whether it experienced a significant decline in gross receipts for the first three quarters in 2021. ABC should use the fourth quarter of 2020 for comparison to the fourth quarter of 2021 to determine whether it experienced a significant decline in gross receipts.

For a discussion of the ERC, see Parker Tax ¶106,460.

Disclaimer: This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change. Parker Tax Publishing guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. Parker Tax Publishing assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein.

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