911--LEHR 781-790
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NOTES 781 Tax Lawyer, Vol. 53, No. 3 NOTE ASSESSING EMPLOYER FICA TAX ON THE ESTIMATED AGGREGATE UNREPORTED TIPS OF EMPLOYEES: QUIETWATER ENTERTAINMENT, INC. V. UNITED STATES In Quietwater Entertainment, Inc. v. United States,1 the U.S. District Court for the Northern District of Florida held that the Service is not authorized to assess an employer’s share of FICA taxes based on an estimate of employees’ aggregate unreported tips. The court distinguished a recent Eleventh Circuit decision...