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NOTES 971 Tax Lawyer, Vol. 55, No. 4 NOTE SUPREME COURT TIPS BALANCE IN FAVOR OF THE SERVICE BY AUTHORIZING AGGREGATE ASSESSMENT OF UNREPORTED EMPLOYEE TIPS: UNITED STATES V. FIOR D’ITALIA, INC. In United States v. Fior d’Italia1, the Supreme Court held that the Service is authorized to impose a Federal Insurance Contributions Act (FICA) tax on a restaurant based on an aggregate estimate of the unreported tips of the restaurant’s tipped employees.2 The Court reasoned that because section 6201(a)...