Morrison Restaurants, Inc. v. United States
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
BIRCH, Circuit Judge:
This appeal presents the issue of whether the Internal Revenue Service (“IRS”) has authority under 26 U.S.C. § 3121(q) to assess the employer’s share of Federal Insurance Contribution Action (“FICA”) taxes on the unreported tips of its restaurant employees on an aggregate basis without determining the underreporting by the individual employees and crediting their wage history accounts. The district court granted summary judgment in favor of Morrison Restaurants and held that the assessment of the employer’s share of FICA taxes on unreported tips in the aggregate was…
2Cases cited7 opinions
- Flemming v. NestorSupreme Court of the United States · 1960
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- United States v. Charles R. McLemoreCourt of Appeals for the Eleventh Circuit · 1994
- McQuatters v. CommissionerUnited States Tax Court · 1973
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