Kraatz & Craig Surveying, Inc. v. Comr., 134 T.C. 167 (2010)

(plaintiff corporation provides land surveying services, but does not provide any services that are required to be performed by licensed engineers; IRS took position that such services are "engineering services" under Treas. Reg. Sec. 1.448-1T(e)(4)(i) and, thus, the corporation is a qualified personal service corporation subject to a 35 percent tax rate; court agrees that land surveying is in the field of engineering and court not bound to follow state (Tennessee) law under I.R.C. Sec. 448(d)(2) which distinguishes land surveying from engineering by requiring separate licenses for each service; temporary regulation upheld as valid).