Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?

By Phil Karter The Quality Stores employment tax refund case was argued before the Supreme Court on January 14, 2014.  An explanation about the issue at stake can be found in prior Taxblawg.net postings.  Although the outcome of the case remains in doubt, the possibility of a taxpayer victory means that employers should start thinking … More Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?

Supreme Court Accepts Certiorari In Quality Stores

By Phil Karter The U.S. Supreme Court today accepted the government’s petition for certiorari in  United States v. Quality Stores (Civil No. 10-1563, 6th Cir. 2012), a case in which the Sixth Circuit affirmed a lower court’s decision that supplemental unemployment compensation benefit (SUB) payments are not taxable as wages and are consequently exempt from FICA taxes.  In accepting … More Supreme Court Accepts Certiorari In Quality Stores

Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

By Phil Karter Any corporate tax executive who has ever been involved in contesting an audit adjustment knows all too well how unfavorable documents relating to the subject of the adjustment – particularly improvident comments reflected in email correspondences – can be an ongoing impediment to resolving a tax dispute from the audit phase right … More Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

Supreme Court’s Review of Valuation Misstatement Penalty Leaves the Door Open for Appellants

By David J. Shakow On March 25, the Supreme Court accepted certiorari in U.S. v. Gary Woods.  (Supreme Court order) The issue presented to the Court arose from a split in the Circuits over whether a taxpayer can avoid the valuation misstatement penalties of section 6662(e) and (h) by conceding that there was no economic substance … More Supreme Court’s Review of Valuation Misstatement Penalty Leaves the Door Open for Appellants

Squib Note: The Opera Isn’t Over Yet on FICA Tax Refunds Until The Supreme Court Sings

By Phil Karter and John Hackney In a blog posting earlier this year, we talked about the Sixth Circuit’s decision in United States v. Quality Stores (Civil No. 10-1563, 6th Cir. 2012) affirming a lower court’s decision that supplemental unemployment compensation benefit (SUB) payments are not taxable as wages and are consequently exempt from FICA … More Squib Note: The Opera Isn’t Over Yet on FICA Tax Refunds Until The Supreme Court Sings

Sixth Circuit Moves The Ball Forward For Companies Seeking FICA Tax Refunds On Supplemental Unemployment Compensation Benefit Payments

By Phil Karter and John Hackney For companies that have implemented employee layoffs in the past several years and made severance payments to terminated employees, the prospect of eligibility for federal tax refunds for any FICA taxes withheld from such payments took another step forward with the Sixth Circuit’s January 4th denial of the government’s … More Sixth Circuit Moves The Ball Forward For Companies Seeking FICA Tax Refunds On Supplemental Unemployment Compensation Benefit Payments