San Francisco Baseball Associates L.P. v. United States
Opinion
Opinion
Conti, J.
ORDER RE MOTIONS FOR SUMMARY JUDGMENT
I. INTRODUCTION
In the above-captioned case, Plaintiff San Francisco Baseball Associates L.P. (the “Giants”) brings an action against Defendant United States of America (the “Government”) for the refund of employment taxes paid by the Giants in the 1995 calendar year. The dispute arises out of payments made to seven former Giants baseball players from a $280 million settlement of three grievances filed by the Major League Baseball Players’ Association (the “Players’ Association”) against 26 Major League Baseball Clubs (the “Clubs”) for the violation of a collective bargaining agreement. The Giants contend that these payments are damages rather than wages, and thus are not subject to taxation pursuant to the Federal Insurance Contribution Act (“FICA”) and the Federal Unemployment Tax Act (“FUTA”). The Giants also contend that, even if the payments are wages, they should be allocated to the 1986 and 1987 calendar years to which the payments relate rather than to the 1995 calendar year during which the payments were actually made. Now before the Court are both parties’ motions for summary judgment.