The Supreme Court ruled yesterday that the Internal Revenue Service can seize the assets of a joint bank account even though only one of the depositors owes overdue taxes.
The court decided, 5 to 4, that the Internal Revenue Code permits the IRS to demand assets from a joint bank account regardless of whether any of the money belongs to the delinquent taxpayer.
At issue in the case, United States v. National Bank of Commerce, was whether a person's unknown interest in a joint account constituted "property or the right to property" under the law.
The case arose in 1979 after the government accused Roy Reeves of Pine Bluff, Ark., of failing to pay taxes of $856.61.
The next year, the IRS attempted to seize $1,302.56 in back taxes and penalties from a savings account and a checking account at the National Bank of Commerce. Both accounts bore the names of "Roy Reeves or Ruby Reeves or Neva R. Reeves."
Although all three had access to funds in the accounts totaling $1,563.26, it was unclear who actually owned the money.
The National Bank had maintained that it did not have to surrender any money to the IRS because Roy Reeves did not possess it or have rights to it.
A federal appellate court agreed with the bank, but its decision was reversed yesterday by the high court.
Justice Harry A. Blackmun, writing for the court, said "common sense dictates that a right to withdraw qualifies as a right to property" for purposes of the Internal Revenue Code.
"The IRS acquires whatever rights the taxpayer himself possesses," the court said.
The court noted that third parties may contest the seizure at an administrative or judicial hearing.
Justice Lewis F. Powell Jr., in a dissent, said the court's decision "substantially ignores the property rights of nondelinquent taxpayers," and "often will place the property rights of third parties in serious jeopardy."
The majority opinion by Blackmun was joined by Chief Justice Warren E. Burger and Justices Byron R. White, William H. Rehnquist and Sandra Day O'Connor.
Joining Powell in dissent were Justices William J. Brennan, Thurgood Marshall and John Paul Stevens.
In another case yesterday, the court gave consumers a significant victory by ruling, 8 to 0, that states may grant their courts broad authority to hear class-action suits. It said state courts can exercise such authority given to them by their legislatures even though most of the members of the class have no connection with the state hearing the case.
The decision, Phillips Petroleum Company v. Shutts is significant because the jurisdiction of federal courts in class-action suits has been narrowed in recent years, often closing their doors to actions involving large classes of members each with relatively small claims.
The case reached the court after the Kansas Supreme Court ruled last year that it had jurisdiction over a class action involving the interest on royalty payments for leases of land bearing natural gas and controlled by the Phillips Petroleum Co. More than 99 percent of the leases, and about 97 percent of the 28,000 members of the class, had no connection with Kansas.
Powell did not participate in the case.
In other action the court, by a vote of 6 to 2, avoided making a major constitutional ruling in a case involving the detention of about 2,000 Haitians after they arrived in the United States in 1981.
A federal appeals court ruled last year that the refugees had no constitutional rights concerning applications for admission, asylum or parole.
Rehnquist said in the court's opinion in Jean v. Nelson that the appeals court should not have addressed the constitutional issues because current laws and regulations are adequate to make nondiscriminatory parole decisions.