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NOTES 881 Tax Lawyer, Vol. 55, No. 3 NOTE EVALUATING SECTION 62 ACCOUNTABLE PLANS AND THE REASONABLE RELIANCE DEFENSE: SHOTGUN DELIVERY, INC. V. UNITED STATES In Shotgun Delivery, Inc. v. United States,1 the Ninth Circuit Court of Appeals affirmed a district court’s grant of summary judgment against a courier service, agreeing that automobile expense allowances paid to the service’s drivers were wages subject to withholding, rather than tax-exempt reimbursements under a section 62 “accountable...

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