Erlich v. United States

MEMORANDUM OPINION AND ORDER

WOLSKI, Judge.

The motions before the Court concern whether the plaintiffs, married United States citizens who jointly file their tax returns, are allowed foreign tax credits under 26 U.S.C. § 901(b)(1) for certain taxes paid to France during tax years 2004 through 2006. Both sides have moved for partial summary judgment. For purposes of these motions, five different categories of these taxes are assumed to be social security taxes,1 requiring the Court to determine whether Section 317(b)(4) of the Social Security Amendments of 1977 (“SSA 1977”) precludes plaintiffs…