Legal Opinion

Ford Motor Co. v. United States

United States Court of Federal Claims

Decided August 13, 2010No. 07-658TPublishedCited by 6 opinions

1Opinion of the Court

MEMORANDUM OPINION AND ORDER BASED ON IN CAMERA REVIEW

WILLIAMS, Judge.

This matter comes before the Court on Plaintiff’s motion to compel production of documents withheld under the deliberative process privilege. For the reasons stated below, the Court denies Plaintiffs motion.

Background1

In this action, Ford Motor Company (“Ford”) seeks a refund of $44,292,652 in taxes paid in 1996 and 1999, pursuant to the Federal Insurance Contributions Act (“FICA”), which imposes an excise tax on wages. 26 U.S.C. §§ 3101 et seq.2 The Internal Revenue Code defines wages for FICA purposes as “all remuneration…

2Cases cited52 opinions

  1. Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
  2. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  3. National Labor Relations Board v. Sears, Roebuck & Co.Supreme Court of the United States · 1975
  4. Kerr v. United States Dist. Court for Northern Dist. of Cal.Supreme Court of the United States · 1976
  5. Coastal States Gas Corporation v. Department of EnergyCourt of Appeals for the D.C. Circuit · 1980

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3Cited by6 opinions

  1. Heffernan v. AzarCourt of Appeals for the D.C. Circuit · 2018
  2. Delphi Corp. v. United StatesDistrict Court, S.D. New York · 2011
  3. Fairholme Funds, Inc. v. United StatesUnited States Court of Federal Claims · 2016
  4. Estes v. United StatesUnited States Court of Federal Claims · 2016
  5. Heffernan v. United States Department of Health and Human ServicesDistrict Court, District of Columbia · 2019

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