Western Reserve Academy v. United States

The government appeals from an adverse district court decision, 619 F.Supp. 394 which followed the filing of cross-motions for summary judgment based on stipulated facts. Thus, the issue before this court is precisely the same as that presented to the district court — whether cash tuition assistance awards paid to Western Reserve faculty members for use in defraying the undergraduate college expenses of their children constitute compensation for which Western Reserve is required to pay withholding and Federal Insurance Contribution Act (FICA) taxes.

The district court rejected Western…