Extension Obtained to Respond in Quality Stores
The taxpayer has obtained an extension until July 31 to respond to the government’s petition for certiorari in Quality Stores.… Read More
View ArticleSupreme Court Schedules Quality Stores for Conference
The taxpayer has filed its brief in opposition in the Supreme Court in Quality Stores. (See our earlier report on the certiorari petition here.) The government has the option of filing a reply...
View ArticleReply Brief Filed in Quality Stores
Linked below is the government’s reply brief in support of its petition for certiorari. The reply attempts to counter the taxpayer’s argument that the conflict between the Sixth Circuit and the...
View ArticleSupreme Court Grants Certiorari in Quality Stores
The Supreme Court, not surprisingly, granted cert this morning in the Quality Stores case. As we have previously reported (see our prior coverage here), the Court is now poised to resolve a conflict...
View ArticleOral Argument Scheduled in Quality Stores
The Supreme Court has scheduled oral argument in the Quality Stores case for the afternoon of Tuesday, January 14. Two other cases will be argued in the morning session, and the Court will then break...
View ArticleSupreme Court Briefing Underway in Quality Stores
The government has filed its opening brief in the Quality Stores case, which involves the question whether severance payments made pursuant to an involuntary reduction in force are subject to FICA...
View ArticleTaxpayer Brief Filed in Quality Stores
The taxpayer has filed its responsive brief in Quality Stores, setting forth both its basic position that SUB payments are not FICA “wages” and responding in detail to the government’s contrary...
View ArticleBriefing Complete in Quality Stores
The government’s reply brief has now been filed in Quality Stores, completing the briefing. The Court will hear oral argument on January 14. Also linked below are three amicus briefs that have been...
View ArticleSupreme Court Hears Oral Argument in Quality Stores
The Supreme Court heard oral argument on January 14 in Quality Stores. Whether it was because of a lack of interest in the subject matter or because it was the third argument of the day at the...
View ArticleGovernment Prevails in Quality Stores
The Supreme Court today ruled 8-0 in favor of the government in the long-running Quality Stores litigation, holding that severance payments are taxable FICA wages, even if they fall within the category...
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