Quality Stores and the Status of Revenue Rulings

Patrick J. Smith

Ivins, Phillips & Barker

September 9, 2013

Tax Notes, Vol. 140, pp. 1089-1097, Sept. 9, 2013

The issue in Quality Stores is whether the supplemental unemployment compensation benefits that are excluded from taxable wages for FICA purposes are determined by a series of IRS revenue rulings, as the government contends, or by the statutory definition of supplemental unemployment compensation benefits, as the taxpayer contends. The government does not explain how revenue rulings can provide the definitive legal answer. Nor does it even attempt to defend the correctness of the positions expressed in the rulings. The taxpayer’s position is coherent and sensible, whereas the government presents no supportable alternative. As a result, the taxpayer’s position clearly must be preferred.

Number of Pages in PDF File: 9

Keywords: tax, administrative law, Chevron, Mead, IRS, revenue rulings

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Date posted: September 10, 2013  

Suggested Citation

Smith, Patrick J., Quality Stores and the Status of Revenue Rulings (September 9, 2013). Tax Notes, Vol. 140, pp. 1089-1097, Sept. 9, 2013. Available at SSRN: http://ssrn.com/abstract=2323654

Contact Information

Patrick J. Smith (Contact Author)
Ivins, Phillips & Barker ( email )
1700 Pennsylvania Avenue, NW Suite 600
Washington, DC 20006
United States
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