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Rowan CoS., Inc. v. United States, 452 U.S. 247 (1981)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Rowan CoS., Inc. v. United States, 452 U.S. 247 (1981)
Rowan Cos., Inc. v. United States No. 80-780 Argued April 21, 1981 Decided June 8, 1981 452 U.S. 247
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
Syllabus
Petitioner, for its own convenience, provided meals and lodging to its employees working on offshore oil rigs. Petitioner did not include the value of the meals and lodging in computing the employees’ "wages" for the purpose of paying taxes under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA) or withholding the employees’ federal income taxes. Upon audit, the Internal Revenue Service included the value of the meals and lodging in the employees’ "wages" for FICA and FUTA, but not for income tax withholding. In doing so, the IRS acted consistently with Treasury Regulations that interpret the definition of "wages" in FICA and FUTA to include the value of such meals and lodging, whereas the substantially identical definition of "wages" in the income tax withholding provisions is interpreted by Treasury Regulations to exclude this value. Petitioner paid the additional assessment for FICA and FUTA taxes and brought suit in Federal District Court for a refund. The District Court granted summary judgment for the Government, and the Court of Appeals affirmed, holding that the different interpretations of the definition of "wages" was justified by the different purposes of FICA and FUTA, on the one hand, and income tax withholding, on the other.
Held: The Treasury Regulations interpreting the definition of "wages" in FICA and FUTA to include the value of the meals and lodging are invalid, for they fail to implement the statutory definition in a consistent or reasonable manner. The plain language and legislative histories of the relevant statutes indicate that Congress intended its definition of "wages" to be interpreted in the same manner for FICA and FUTA as for income tax withholding. Pp. 250-263.
624 F.2d 701, reversed.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, BLACKMUN, REHNQUIST, and STEVENS, JJ., joined. WHITE, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 263.
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Chicago: U.S. Supreme Court, "Syllabus," Rowan CoS., Inc. v. United States, 452 U.S. 247 (1981) in 452 U.S. 247 452 U.S. 248. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=ZN3RBKJSCNMCXXM.
MLA: U.S. Supreme Court. "Syllabus." Rowan CoS., Inc. v. United States, 452 U.S. 247 (1981), in 452 U.S. 247, page 452 U.S. 248. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=ZN3RBKJSCNMCXXM.
Harvard: U.S. Supreme Court, 'Syllabus' in Rowan CoS., Inc. v. United States, 452 U.S. 247 (1981). cited in 1981, 452 U.S. 247, pp.452 U.S. 248. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=ZN3RBKJSCNMCXXM.
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