Alan Horowitz was quoted regarding U.S. v. Quality Stores Inc. in a wrap-up of the major tax litigation that ended in 2014. The U.S. Supreme Court backed a long-standing Internal Revenue Service (IRS) policy earlier in the year when it ruled that severance payments are subject to Federal Insurance Contributions Act taxes. Although the ruling was a loss for employers and employees alike, Horowitz said it does lend some certainty to multistate employers who had grappled with a split between the Sixth and Federal Circuits. "You had nationwide employers who were subject to different rules in different states, and they needed to manage their payroll in a way that was efficient. Even though they'll be subject to the tax, they're better off than they were through the uncertainty that persisted," he said.