Operating Engineers v. United States

CourtDistrict Court, N.D. California
DecidedFebruary 10, 2023
Docket3:21-cv-02724
StatusUnknown

This text of Operating Engineers v. United States (Operating Engineers v. United States) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Operating Engineers v. United States, (N.D. Cal. 2023).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 6 OPERATING ENGINEERS LOCAL Case No. 21-cv-02724-AGT UNION NO. 3, 7 Plaintiff, ORDER GRANTING GOVERNMENT’S 8 MOTION FOR SUMMARY v. JUDGMENT 9 UNITED STATES OF AMERICA, Re: Dkt. No. 23 10 Defendant.

11 12 During the last two quarters of 2018 and the first quarter of 2019, Operating Engineers 13 Local Union No. 3 (“OE3”) failed to fulfill its federal tax obligations with respect to the funds it 14 withheld from its employees’ wages. By statute, these failures triggered the assessment of 15 substantial penalties by the Internal Revenue Service (“IRS”), which OE3 paid in full. After 16 unsuccessfully seeking reimbursement from the IRS, OE3 filed this suit seeking a refund of the 17 penalties paid, plus interest, on the grounds that its failure to timely file, pay, and deposit payroll 18 taxes during the periods at issue was “due to reasonable cause and not due to willful neglect.” 19 26 U.S.C. §§ 6651(a), 6656(a). The Government now moves for summary judgment, arguing that 20 OE3 lacked “reasonable cause” as a matter of law for its payroll tax delinquencies. The motion 21 was argued and submitted on September 16, 2022. For the reasons explained below, the 22 Government’s motion is granted. 23 I. BACKGROUND 24 A. Statutory Framework 25 Under the Internal Revenue Code, employers such as OE3 are required to deduct and 26 withhold federal social security and income taxes from their employees’ wages. 26 U.S.C. 27 §§ 3102(a), 3402(a). These taxes must be held by the employer in a special trust fund for the 1 taxes required to be withheld and is required to report the amounts of withheld taxes on its 2 quarterly payroll tax returns, Form 941. 26 U.S.C. §§ 3403, 6011(a); 26 C.F.R. §§ 31.6011(a)-1, 3 31.6011(a)-4(a)(1). These returns must be filed with the IRS on the last day of the month that 4 follows the date that payroll taxes accrued in the preceding period. 26 C.F.R. § 31.6071(a)- 5 1(a)(1). For example, for first quarter tax liabilities that accrued from January 1 to March 31, the 6 payroll tax return for that quarter is due April 30. Payment of any tax liability is due the same day 7 the return is due. 26 U.S.C. § 6151(a). In the interim, withheld taxes that are reported on Form 8 941 must be deposited either monthly or semi-weekly in an authorized government depository 9 account. 26 U.S.C. § 6302; 26 C.F.R. § 31.6302-1. 10 The Internal Revenue Code calls for the assessment of mandatory penalties upon any 11 taxpayer who fails to file a required return, 26 U.S.C. § 6651(a)(1), fails to pay the amount of tax 12 due, 26 U.S.C. § 6651(a)(2), or fails to deposit the appropriate amount of tax in a government- 13 authorized depository account, 26 U.S.C. § 6656(a). These statutory penalties are explicitly 14 waived, however, if the taxpayer can show “such failure is due to reasonable cause and not due to 15 willful neglect.” Id. 16 B. Factual History 17 OE3 is the largest construction local union in the United States, representing over 37,000 18 members. Dkt. 1, Compl. ¶ 2. OE3 had a pristine record of over 100 years of federal tax law 19 compliance, until the tax periods ending September 30, 2018 (“Q3 2018”), December 31, 2018 20 (“Q4 2018”), and March 31, 2019 (“Q1 2019”). Despite having sufficient funds to cover its tax 21 liabilities during those three periods, OE3 failed to make timely payroll deposits. OE3 also failed 22 timely to file its payroll tax return and pay its tax liability for Q3 2018. As a result of these 23 failures, the IRS assessed statutory penalties against OE3 as follows:

24 Tax Period Internal Revenue Code § Penalty Amount Q3 2018 26 U.S.C. § 6651(a)(1) – Failure to file $258,023.31 25 Q3 2018 26 U.S.C. § 6651(a)(2) – Failure to pay $19,372.43 26 Q3 2018 26 U.S.C. § 6656 – Failure to deposit $114,677.03 Q4 2018 26 U.S.C. § 6656 – Failure to deposit $107,914.99 27 Q1 2019 26 U.S.C. § 6656 – Failure to deposit $87,309.40 1 See Dkt. 23-2. OE3 paid the penalties plus accrued interest, then sought a refund from the IRS on 2 the ground that it had “reasonable cause” for its failure to timely file, pay, and deposit payroll 3 taxes. Specifically, OE3 claimed that it was “completely disabled and incapacitated with regard to 4 its tax obligations” due to the “mental disability” of the employee who was responsible for its 5 payroll tax duties, Angela Rose. See Compl. Exs. A, B, D, E, F (Claims for Refund and Requests 6 for Abatement). The IRS denied OE3’s claims for refund, explaining that “the fact that your 7 employee handled all of your tax matters isn’t a mitigating circumstance. You are responsible for 8 making a timely deposit and someone else’s failure can’t be a basis for removing your penalty.” 9 Id. Ex. C at 18–19. 10 OE3 subsequently filed this action to compel a refund of the $587,297.16 in penalties it 11 paid to the IRS, plus statutory interest. OE3’s complaint asserts a single claim, based on the same 12 allegations asserted in its claims for refund filed with the IRS: “The failure of [OE3] to timely file 13 and pay payroll taxes and make proper tax deposits due for the tax periods ending September 30, 14 2018; December 31, 2018; and March 31, 2019 was not due to willful neglect but due to 15 reasonable cause.” Id. ¶ 22. According to OE3, the “events which ultimately led to [its] failure to 16 comply with its tax payment and reporting obligations stem from the [June 2018] resignation of 17 then Accounting Manager Lilian Morata and actions by then Finance Director/Controller [Angela 18 Rose].” Id. Ex. A at 7. 19 At all relevant times, OE3 was governed by an executive board comprised of six officers: 20 the Business Manager, Russell Burns, who was “basically the CEO of the union” and oversaw 21 OE3’s entire operation, and the President, Vice President, Treasurer, Financial Secretary, and 22 Recording Corresponding Secretary, who all reported to Burns. See Dkt. 23-3, Burns Dep. at 23 12:6–13:25; Dkt. 23-4, Reding Dep. at 10:6–7. As Business Manager, Burns had final say on all 24 union matters and the right to hire and fire everybody on OE3’s staff. See Reding Dep. at 10:6– 25 11. Burns also had supervisory control over OE3’s accounting department, which was responsible 26 for OE3’s payroll tax obligations, and he was the direct supervisor of both the Finance 27 Director/Controller and the Accounting Manager.

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