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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Lansden v. Marsh

This case addresses the constitutionality of taxing Social Security benefits. Plaintiffs challenged the Internal Revenue Service's imposition and collection of a tax on their 1992 Social Security benefits, arguing it violated the United States Constitution's prohibition against direct taxes without apportionment, the doctrine of intergovernmental tax immunity, and was unconstitutionally vague. The Court granted the Defendant's motion for summary judgment and denied the Plaintiffs' cross-motion. It held that Social Security benefits are an "accession to wealth" and thus taxable income under the Sixteenth Amendment, not a return of property. The Court also rejected the intergovernmental tax immunity argument, finding no implied contract, and determined that the relevant tax statute was not void for vagueness.

TaxationSocial Security BenefitsIncome TaxDirect TaxApportionmentSixteenth AmendmentIntergovernmental Tax ImmunityVoid for Vagueness DoctrineSummary JudgmentConstitutional Law
References
18
Case No. MISSING
Regular Panel Decision

Psaty & Fuhrman, Inc. v. New York State Tax Commission

Petitioner, a general contracting firm involved in the construction of the Nelson A. Rockefeller Empire State Plaza, faced a personal income tax assessment for additional payments made to 16 employees. These payments, characterized as per diem living and travel allowances, did not have New York State income taxes withheld. The State Tax Commission, after an audit and hearing, ruled these were supplemental wages subject to withholding tax, not reimbursements. Petitioner initiated a CPLR article 78 proceeding, bearing the burden of proof, to challenge this determination. The court, noting the payments lacked a fixed formula and some recipients lived locally, found the respondent acted reasonably. The determination was confirmed, and the petition dismissed.

Personal Income TaxWithholding TaxSupplemental WagesPer Diem PaymentsTravel AllowanceLodging AllowanceCPLR Article 78Burden of ProofTax DeficiencyState Tax Commission
References
1
Case No. 13-14-00670-CV
Regular Panel Decision
Jan 08, 2015

Texas Municipal League Intergovernmental Risk Pool v. Lloyd K. Aldridge

Aldridge is seeking recovery of attorney's fees for two tasks: negotiating a settlement for policy limits involving a prior injury, and pursuing recovery for the compensation carrier by preventing the running of the statute of limitations. The Texas Municipal League Intergovernmental Risk Pool (TMLIRP) has filed a cross-claim against Lynn Hillyer, the defendant driver, and Aldridge argues that TMLIRP waived sovereign immunity by filing for affirmative relief. Aldridge also asserts that TMLIRP is not a legitimate intergovernmental risk pool as it was not created by governmental units. The brief argues for the proper allocation of settlement funds, including attorney's fees and expenses, from the $30,000 policy limits offered by Hillyer's insurer, to reimburse TMLIRP for its subrogation interest.

SubrogationSovereign ImmunityIntergovernmental Risk PoolAttorney's FeesSettlement AllocationDeclaratory JudgmentAppellate ProcedureTexas Government CodeTexas Labor CodeStatute of Limitations
References
12
Case No. 05-18-00239-CV
Regular Panel Decision
Oct 02, 2019

Barbara Stegall, Individually, and on Behalf of the Estate of Joe Stegall v. TML Multistate Intergovernmental Employee Benefits Pool, Inc., and UMR, Inc.

This dissenting opinion argues against the majority's conclusion that TML, an intergovernmental self-insurance risk pool, and its third-party administrator, UMR, are governmental entities entitled to immunity from Barbara Stegall's tort claims. Justice Partida-Kipness contends that the 'governmental–proprietary distinction,' typically applied to municipalities, should extend to TML and UMR because they perform both governmental and proprietary functions. The dissent asserts that the appellees' actions related to adjusting Mr. Stegall's insurance claim, such as denying chemotherapy and withholding coverage authorizations, constituted proprietary functions, not governmental ones. Consequently, the dissenting justice believes TML and UMR should not be immune from tort claims arising from these actions and would reverse the granting of the appellees’ pleas to the jurisdiction.

Governmental ImmunityProprietary FunctionsIntergovernmental Risk PoolTort ClaimsSovereign ImmunityTexas LawMunicipalitiesClaims AdjustmentThird-Party AdministratorImmunity Waiver
References
9
Case No. MISSING
Regular Panel Decision

Rosenbloom v. New York State Tax Commission

The petitioner, a real estate appraiser, challenged an unincorporated business tax assessment imposed by the State Tax Commission for the years 1967-1973. The court referenced a prior ruling (Matter of Rosenbloom v State Tax Comm.) which established that the petitioner's activities did not constitute a profession, thus not exempting him from the tax. Finding no new evidence to warrant a change in position, the court upheld the commission's determination regarding the professional exemption. Furthermore, the petitioner's attempt to deduct the fair value of his wife's uncompensated services was denied, as the expense was neither paid nor incurred during the taxable year, failing to meet the criteria for ordinary and necessary business deductions. Consequently, the determination was confirmed, and the petition was dismissed.

real estate appraiserunincorporated business taxtax assessmentprofessional exemptionbusiness expenseCPLR Article 78State Tax CommissionAlbany Countyprior precedentdeduction denial
References
2
Case No. MISSING
Regular Panel Decision

Craftmatic Comfort Manufacturing Corp. v. New York State Tax Commission

Petitioner, a Pennsylvania corporation selling adjustable beds, challenged a sales and use tax assessment for the period of March 1978 to February 1981. The corporation argued that sales of its beds, when prescribed by a physician, should be exempt as medical equipment under Tax Law § 1115 (a) (3). The respondent's determination disallowed this exemption, claiming the beds were not primarily used for medical purposes. The court, however, found the respondent's decision lacked substantial evidence, citing approvals from the Workers’ Compensation Board, Medicare, and the FDA, all of which classified the beds as medical devices or hospital beds. Consequently, the court annulled the portion of the determination denying the exemption for prescription sales and remitted the case for further proceedings.

Sales TaxUse TaxMedical Equipment ExemptionHospital BedsPhysician's PrescriptionSubstantial EvidenceTax LawCPLR Article 78Administrative ReviewTax Assessment
References
5
Case No. MISSING
Regular Panel Decision

Wortman v. State Tax Commission

The petitioner, a salesman for Madison Sportswear and Wardrobe Makers, was assessed unincorporated business taxes for the years 1971-1974 by the State Tax Commission. He worked on a straight commission, maintained a home office, and received no employee benefits. Despite some evidence suggesting an employer-employee relationship, the Commission determined his activities constituted an unincorporated business, making his earnings subject to the tax. The court, in a CPLR article 78 proceeding, confirmed the Commission's determination, dismissing the petition.

Unincorporated Business TaxSalesmanCommission-basedEmployer-Employee RelationshipTax LawState Tax CommissionCPLR Article 78Tax LiabilityBusiness Expenses
References
3
Case No. MISSING
Regular Panel Decision

Pochter v. State Tax Commission

The case concerns Leonard Pochter, an outside commission salesman, challenging a State Tax Commission determination classifying him as an independent contractor, thus subjecting him to unincorporated business tax for 1966-1972. Pochter contended he was an employee of two wholesale apparel firms, which would exempt him from the tax. Despite some company restrictions and requirements, the Commission found a lack of substantial control over his sales methods. The court affirmed the Commission's decision, citing insufficient evidence of employer supervision to establish an employee relationship, thereby dismissing Pochter's petition.

unincorporated business taxindependent contractor statusemployee statuscommission salesmantax assessmentCPLR Article 78State Tax Commissionapparel industryemployer control testtax law interpretation
References
10
Case No. 03-98-00169-CV
Regular Panel Decision
Jun 17, 1999

Texas Workers' Compensation Commission and Subsequent Injury Fund v. Texas Municipal League Intergovernmental Risk Pool

The Texas Municipal League Intergovernmental Risk Pool (Risk Pool) challenged the constitutionality of specific provisions within the Texas Workers' Compensation Act and related Texas Workers' Compensation Commission (TWCC) rules. These provisions mandated contributions to the Subsequent Injury Fund, which the Risk Pool argued violated constitutional restrictions on political subdivisions lending credit or granting public money, and imposing state ad valorem property taxes. The trial court initially sided with the Risk Pool, declaring the requirements unconstitutional as applied to its members. On appeal, the Court of Appeals addressed the Risk Pool's standing and the core constitutional arguments. The appellate court characterized the mandatory contributions as analogous to a custodial escheat statute, where the state assumes custody of unclaimed death benefits rather than gaining absolute ownership. Consequently, the court reversed the trial court's judgment, concluding that the Risk Pool failed to meet its burden for an "as applied" constitutional challenge, notably by not asserting a limitations defense.

Workers' Compensation ActSubsequent Injury FundDeclaratory JudgmentConstitutional ChallengeAs-Applied ChallengeAssociational StandingAcceptance of Benefits DoctrineEscheat LawCustodial EscheatUnclaimed Death Benefits
References
18
Case No. MISSING
Regular Panel Decision

City of New York v. State

This case addresses the constitutionality of Chapter 5 of the Laws of 1999, which attempted to rescind New York City's commuter tax for New York State residents while retaining it for out-of-State commuters. The City of New York challenged the statute on home rule grounds, while residents of New Jersey and Connecticut, along with the State of Connecticut, argued it violated the Federal Constitution's Privileges and Immunities and Commerce Clauses. The Court held that Chapter 5 did not violate state home rule provisions. However, it found the statute unconstitutional under the Federal Privileges and Immunities and Commerce Clauses due to its discriminatory treatment of out-of-State commuters. Consequently, the 'poison pill' provision of Chapter 5 took effect, leading to the repeal of the entire New York City commuter tax as of July 1, 1999.

Commuter TaxHome Rule ProvisionsPrivileges and Immunities ClauseCommerce ClauseConstitutional ChallengeState TaxationTax DiscriminationNew York CityLegislative PowerStatutory Repeal
References
40
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