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Will The IRS Be Auditing You in 2004?

By Ken Cassidy

Instead of writing my regular column concerning the choices of employers and booth renters I’d like to present the information I received in a meeting with the Internal Revenue Service (IRS). The message was very clear to me that the IRS will be concentrating on auditing the beauty and barbering industry after April 15, 2004 and the reason is very clear as I see it.


As a stylist for the past 33 years and as a licensed cosmetology instructor of the past 24 years I have watched what has happened in our industry. What the IRS wants to do will affect every area of our industry from the manufacturers, distributors, sales consultants, business owners, their staff of employees and all the independent owners out there whether you call yourself a booth renter or an independent contractor or whatever creative title you have given yourself or your staff.


The truth is the IRS would like to see that everyone is in an employee/employer relationship for one simple reason: The government is out to collect as much unreported income as they can from every industry but specifically the beauty and barbering industry.


So here is their plan of action. First and foremost it is unfortunate that so many our industry does not declare tips as income. The IRS and more states are looking to have you declare anywhere from 7.5% to 20% of your income as having been derived from tips or gratuities. The IRS thinks they are losing anywhere from 17 to 20 million dollars from unreported income based on a study made several years ago. They believe that a large portion of that revenue loss is derived from tips and other sources that are unreported.


Our industry shifted into the booth rental market in the early 1990s because of two distinctive market reasons; one being the economic recession, the other reason, the major shortage of people entering into the beauty industry. This booth rental explosion caught on so fast because it was a way to save salon owners from losing everything they had worked so hard for financially in their lives. As an industry, we lost over 60% of the beauty schools and over 10,000 salons in the 90s and are continuing to lose me even today.


Booth renting, as it was becoming to be known in our industry, was a completely different structure than the IRS had ever known or existed in any other industry. To them they only had tax auditing guidelines in the area of contract labor. Seven years back the IRS created a division to oversee cash based businesses which included the beauty industry. The IRS has a tax compliance division to offer guidance and compliance for the salon, spa and barbering industry.
The IRS has organized several areas of that compliance. First they have been teaching tax compliance workshops at all the major trade shows for the past 3 years to make us aware of our tax responsibilities as an employer, an employee and as a booth renter/independent contractor (self-employed.)


The IRS had created a manual several years back which has been updated, to audit the beauty and barbering industry. The auditing agents do not care about what hat you are wearing or what title you have given yourself. In an audit with an employer with employees for instance, they will ask three main questions: One how many hours and days of a week are you open? Secondly what do you charge for services? And thirdly, how much time do you allow for an appointment?
After they retrieve your banking records to uncover the tip percentage and any other income you should have declared among other things, the rest is history from the employer/employee side. From the Booth Rental side all of the same rules apply with the exception that IRS and your State wants to see a clear cut separation between the business owner/landlord and the booth renter when it comes to three main issues: Number one who has Financial Control, number two who has Behavioral Control and number three the Relationship Control to determine whom has the tax responsibility.


Many business owners have their staff misclassified tax wise, which according to the IRS and your own state this would be financially devastating from the amount of money owed in back taxes, penalties and interest that would occur from an audit. That is only the tip of the iceberg because those agencies we have been mentioning through this wake up article will demand that you make all those misclassified individuals employees immediately. What do you think most of those staff members will do? Our educated view is that they will leave your establishment or be forced to do the same because they also can and will be audited.


Last on our list is the Contract Labor title, even though the greatest percentage of our industry does not qualify in the true sense of this category tax wise over 99.5% are incorrectly classified. The IRS is including the category title of booth renting and placing it under contract labor. They would like to see it disappear mostly because of the unreported income, the handling of and how it is not being done correctly. It is all about a paper trail and who really has the tax obligations to pay and by how much, for us this is the real problem.


The final Stage of auditing the beauty and barbering industry is the agreement of the exchange of information that is taking place between the IRS and other states, like who has or has not done the filling of taxes and who is licensed.
We in the beauty and barbering industry need to get our act together on the fundamentals of running a business as a business. Only when we are doing business as a business will the IRS and your state tax issues disappear for the most part—remember three years past.


But wait a minute! Our industry does not have to take all the blame for what has not been working when it comes to being in tax compliance. In the last 8 years we have been in communication with the IRS these tax issues that are plaguing our industry. We have repeatedly requested in writing what they mean by the confusing statements that they have published, to give our industry clear cut definitions on what is and is not acceptable in the tax arena of running a business, especially when it comes to booth renting and contract labor guidelines. On their behalf I must say they are trying to do the right thing in their quest to get us in compliance. They could use the example of the California Franchise Tax Boards guidelines as they are very clear on tax issues.


I’ve traveled all around the United States of America and the one thing in common in the beauty industry is that most people in this great country of ours wants to do things right. They are good law-abiding citizens. All they want to do in playing the game of business is to know what the rules of the game are so they can comply.
As an industry we need to be united. The best way is through some great organizations nationally and through your own state. Get involved in the political movement if in no other way donate some funds to help support the very people that are trying to support you and our industry: TSA, Professional Beauty Federation, especially the California, Chapter, BBSI, ABA, NCA and your own State Chapters.

Ken Cassidy is president of Kassidy’s Management Consulting Company.  We welcome your questions and comments. You may reach Kassidy’s Salon Management Consultants Company at (562) 432-4462 Fax (562) 439-6692 www.kassidys.com . Write to us at 5740 East Second Street - Long Beach, CA 90803 E-mail kassidy122@earthlink.net  or through this publication.