Southland Corp. v. United States

OPINION

SMITH, Chief Judge.

This case is before the court on defendant’s motion for summary judgement. At issue is the allowance of certain targeted jobs credits for taxable years 1982 and 1983. This category of targeted jobs credits was formerly known as the Work Incentive Program (WIN). WIN, enacted by Pub.L. No. 92-178, Dec. 10, 1971, 85 Stat. 554, was codified under § 40, 50A and 50B of the 1954 Internal Revenue Code (IRC). To receive these tax credits for an employee, the employer must have first certified that the employee was eligible for the credit. The WIN pi’ogram allowed an employer…