This section contains the nature of the case and procedural background.

Ps were hockey players with the Minnesota North Stars. Ps created PSCs to represent the business associations. Each P was the sole shareholder, president, and sole director of this personal service corporation. Ps provided their services to the PSCs and the North Stars contracted with the PSCs for Ps' services. Each PSC, in turn, paid each P a salary and contributed the remainder to each PSC's qualified pension plan. Each PSC withheld and paid the applicable federal and state income taxes and timely filed Employers Quarterly Federal Tax Returns and Forms W-2 and W-3. On March 5, 1980, D issued a letter whereby the pension plan established by each was determined to be a qualified pension plan. This upset D greatly who proposed to disallow these pension deductions and elected to tax Ps on the entire amount paid by the Club to the PSC. Ps filed with the Tax Court. The court issued an opinion upholding the deficiencies proposed by D. The Tax Court held that because Ps were members of a hockey 'team,' the requisite control over them -- for purposes of taxation -- was lodged in the Hockey Club, and not in their respective PSCs, with which they had a contractual employment relationship. Ps appealed.

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