Justia Public Benefits Opinion SummariesArticles Posted in Tax Law
Smith v. Tipton County Board of Education
Murdock, an employee with the Tipton County Board of Education, received an email purporting to be from Dr. Bibb, Director of Tipton County Schools, requesting all 2016 employee W-2s and tax information. Murdock responded with a document containing information from the W-2s of every Board employee, including names, addresses, social security numbers, income information, deductions, exemptions, withholdings, tax payments and taxpayer identifying numbers. Murdock then learned that Bibb had not requested the information. The Tipton County Sheriff notified the U.S. Secret Service and the Internal Revenue Service. The Board notified employees of the information release. Smith, a Board employee, filed suit under 26 U.S.C. 6103 and 7431. Section 6103 of the Internal Revenue Code prohibits “any local agency administering a program listed in [§ 6103](l)(7)(D)” from disclosing “return information.” Smith argues that, because the Board works with the Tennessee State Board of Education to administer the National School Lunch Program, the Board provided a qualifying SNAP benefit. The Sixth Circuit affirmed the dismissal of the suit, finding that the Board does not administer a SNAP benefit in providing lunches to students as part of the National School Lunch Program. View "Smith v. Tipton County Board of Education" on Justia Law
W. Hollywood Cmty. Health & Fitness Ctr. v. CA Unemp. Ins. Appeals Bd.
Serban worked as a massage therapist at Voda Spa. Serban and Voda Spa disagree as to why he left that work, but the trial court found Serban had good cause to leave and that finding was not challenged. They also disputed whether Serban was an employee or independent contractor. The California Unemployment Insurance Appeals Board found that he was an employee, not an independent contractor, and the trial court agreed with the Board that its decision was not subject to judicial review because both the California Constitution and the Unemployment Insurance Code bar actions whose purpose is to prevent the collection of state taxes. The court of appeal reversed, agreeing that the case does not challenge the imposition of a tax. View "W. Hollywood Cmty. Health & Fitness Ctr. v. CA Unemp. Ins. Appeals Bd." on Justia Law
University of Texas System, et al. v. United States
UT filed suit against the United States, seeking refund of the Social Security component of FICA taxes it paid with respect to the service of medical residents in 2005. The court affirmed the district court's denial of UT's motion for summary judgment and grant of the United States' motion for summary judgment, concluding that UT's residents are not "students" within the meaning of the student exclusion in Texas's 42 U.S.C. 418 agreement. Section 418 allows states to voluntarily opt-in to the Social Security system by entering into an agreement with the Commissioner of Social Security.View "University of Texas System, et al. v. United States" on Justia Law
Dilley v. City of Missoula
Plaintiff-Appellant John Dilley appealed the grant of summary judgment in favor of Defendant-Appellee City of Missoula. The district court concluded the City acted within its legal authority when it purchased the Missoula Civic Stadium with tax increment financing (TIF) funds designated for urban renewal. The stadium was originally planned and developed by Play Ball Missoula, Inc. (Play Ball), a volunteer, non-profit corporation organized for the purpose of bringing a minor league baseball team to Missoula. In 2000, Play Ball and the City entered a development agreement that permitted Play Ball to finance and construct a stadium on blighted City property and later convey the facility to the City. Plaintiff, acting pro se, filed suit prior to the City's acquisition of the stadium, alleging the planned purchase using TIF funds was an "illegal payoff of private enterprise debt." On appeal, Plaintiff argued that the district court erroneously failed to specify which provision under Title 7, Chapter 15, Part 42 of the Montana Code that permitted the "payoff." He also argued that the City could not make such an expenditure of TIF funds simply because the practice was not prohibited by statute. Finding that the City's use of TIF money to acquire the stadium was a proper exercise of its urban renewal posers, the Supreme Court affirmed the grant of summary judgment in the City's favor. View "Dilley v. City of Missoula" on Justia Law
Family Trust of MA, Inc. v. United States
FTM applied to the IRS for a charitable tax exemption under I.R.C. 501(a) and (c)(3) based on its trustee services. FTM subsequently filed this action seeking a declaration that it was a tax exempt charitable organization after the IRS preliminarily denied it's application. The court affirmed the district court's grant of summary judgment in favor of the government, agreeing with the district court that FTM was not operated exclusively for charitable purposes. View "Family Trust of MA, Inc. v. United States" on Justia Law
Zhang v. United States
Non-resident alien citizens of China sought refunds of taxes paid under the Federal Insurance Contribution Act (FICA), 26 U.S.C. 3101, for work performed as contract workers in the Northern Mariana Islands. A corporation sought a refund of taxes paid for its contract workers in the Islands. The statutory definition of work performed in the United States contains no reference to the Islands. The Claims Court entered judgment on the pleadings in favor of the government. The Federal Circuit affirmed, noting various laws and covenants under which citizens of the Islands are to be treated as citizens of the United States. Congress intended to treat the Islands like Guam is treated for purposes of FICA and to apply both employer and employee FICA taxes to the Islands.