Legal Opinion

CSX Corp. v. United States

Court of Appeals for the Federal Circuit

Decided March 6, 2008No. 2007-5003, 2007-5007PublishedCited by 9 opinions

1Opinion of the Court

BRYSON, Circuit Judge.

This federal tax case calls on us to decide whether payments made to employees by the appellants, an affiliated group of railroad companies that we refer to collectively as CSX, are subject to taxation under the Federal Insurance Contributions Act (“FICA”), 26 U.S.C. §§ 3101-3128, and the Railroad Retirement Tax Act (“RRTA”), id. §§ 3201-3241. The Court of Federal Claims, in a series of three comprehensive opinions, held that certain of the payments at issue were subject to tax and others were not. See 52 Fed.Cl. 208 (2002); 58 Fed.Cl. 341 (2003); 71 Fed. Cl. 630 (2006).…

2Cases cited26 opinions

  1. Dixon v. United StatesSupreme Court of the United States · 1965
  2. Social Security Board v. NierotkoSupreme Court of the United States · 1946
  3. Rowan Cos. v. United StatesSupreme Court of the United States · 1981
  4. Environmental Defense v. Duke Energy CorporationSupreme Court of the United States · 2007
  5. Dickman v. CommissionerSupreme Court of the United States · 1984

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3Cited by9 opinions

  1. United States v. Quality Stores, Inc.Supreme Court of the United States · 2014
  2. Lawrence Mickey v. BNSF Railway Company and Safeco Insurance Company of AmericaSupreme Court of Missouri · 2014
  3. United States v. Quality Stores, Inc. (In Re Quality Stores, Inc.)Court of Appeals for the Sixth Circuit · 2012
  4. United States v. Quality Stores, Inc. (In Re Quality Stores, Inc.)District Court, W.D. Michigan · 2010
  5. United States v. Daniel Edward ScottCourt of Appeals for the Eleventh Circuit · 2008

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