Jackson v. Phinney
This consolidated memorandum opinion addresses three cases seeking refunds of Federal Insurance Contributions Act (FICA) and Federal Unemployment Tax Act (FUTA) taxes. The Internal Revenue Service (IRS) alleged the plaintiffs, who operate shrimp boats in Rockport, Texas, were employers of shrimp captains and deck hands. Plaintiffs argued these workers were independent contractors, not employees, under the common-law tests. The court reviewed factors such as the right to control, right of discharge, integration of work, profit/loss opportunities, permanency, and the parties' own views. Ultimately, the court determined that the plaintiffs were indeed employers and denied the tax refund claims.