Announcement 2015-08 provides guidance on the application of the Supreme Court’s holding in United States v. Quality Stores, Inc. to claims for refund of employment taxes paid with respect to severance payments.  According to the announcement, the IRS will disallow all claims for refund of Federal Insurance Contribution Act (FICA) or Railroad Retirement Tax Act (RRTA) taxes paid with respect to severance payments that do not meet the narrow exclusion of Revenue Ruling 90-72.  This position is consistent with the Supreme Court’s holding inQuality Stores and the Federal Circuit’s holding in CSX Corp. v. United States, that severance payments are both wages for FICA tax purposes and compensation for RRTA tax purposes.