Legal Opinion

United States v. Quality Stores, Inc.

Supreme Court of the United States

Decided March 25, 2014No. 12-1408PublishedCited by 47 opinions

1Opinion of the CourtJustice Kennedy

*143 This case presents the question whether severance payments made to employees terminated against their will are taxable wages under the Federal Insurance Contributions Act (FICA), 26 U.S.C. § 3101 et seq.

The Court of Appeals for the Sixth Circuit held that the payments are not wages taxed by FICA. To reach its holding, the Court of Appeals relied not on FICA's definition of wages but on § 3402( o ) of the Internal Revenue Code, a provision governing income-tax withholding. That conclusion, for the reasons to be discussed, was incorrect.

FICA's broad definition of wages includes the severance…

2Cases cited11 opinions

  1. Stone v. Immigration & Naturalization ServiceSupreme Court of the United States · 1995
  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. Federal Trade Commission v. Mandel Bros.Supreme Court of the United States · 1959
  5. Mississippi Ex Rel. Hood v. AU Optronics Corp.Supreme Court of the United States · 2014

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3Cited by47 opinions

  1. Husky International Electronics, Inc. v. RitzSupreme Court of the United States · 2016
  2. Bufkin v. CollinsSupreme Court of the United States · 2025
  3. BNSF Ry. Co. v. LoosSupreme Court of the United States · 2019
  4. BNSF Railway Company v. United StatesCourt of Appeals for the Fifth Circuit · 2015
  5. Zhurbin v. StateSupreme Court of Delaware · 2014

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