sorenson
secretary
treasury
argued
january
decided
april
internal
revenue
code
irc
allows
individual
responsible
support
child
living
credit
income
taxes
due
equal
certain
percentage
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earned
income
exceed
specified
amount
credit
exceeds
tax
liability
excess
considered
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tax
irc
section
provides
refund
overpayment
person
made
section
requires
amount
overpayment
reduced
amount
payments
assigned
state
section
social
security
act
ssa
directs
secretary
treasury
intercept
tax
refunds
payable
persons
failed
meet
obligations
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state
petitioner
husband
fell
behind
support
payments
child
previous
marriage
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former
wife
latter
upon
applying
welfare
benefits
state
washington
assigned
state
required
aid
families
dependent
children
program
right
collect
unpaid
payments
petitioner
husband
dependent
child
living
filed
joint
federal
income
tax
return
income
attributable
petitioner
wages
unemployment
compensation
benefits
anticipated
refund
based
part
credit
internal
revenue
service
however
notified
certain
amount
anticipated
refund
retained
authority
law
paid
state
washington
petitioner
filed
class
action
federal
district
seeking
declaration
ssa
reach
refund
attributable
excess
credit
district
granted
summary
judgment
government
appeals
affirmed
held
excess
credit
properly
intercepted
applicable
statutes
pp
irc
treatment
credits
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position
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classification
overpayment
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overpayment
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upon
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actually
paid
tax
irc
classification
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actually
made
payment
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payable
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pp
support
petitioner
claim
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intend
program
reach
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credits
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congress
never
mentioned
credit
enacting
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budget
reconciliation
act
added
irc
must
aware
provided
overpayment
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shall
reduced
amount
child
support
include
refunds
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excess
credits
although
goals
credit
reduce
disincentive
work
caused
social
security
taxes
earned
income
stimulate
economy
funneling
funds
persons
likely
spend
money
immediately
provide
relief
families
hurt
rising
food
energy
prices
important
said
congress
concluded
outweigh
goals
served
subsequently
enacted
program
securing
child
support
absent
parents
reducing
number
families
welfare
pp
blackmun
delivered
opinion
burger
brennan
white
marshall
powell
rehnquist
joined
stevens
filed
dissenting
opinion
post
peter
greenfield
argued
cause
petitioner
briefs
bruce
smith
richard
farber
argued
cause
respondents
brief
solicitor
general
fried
assistant
attorney
general
archer
albert
lauber
michael
paup
steven
frahm
joseph
lieberman
attorney
general
connecticut
joseph
dumond
assistant
attorney
general
filed
brief
state
connecticut
amicus
curiae
urging
affirmance
justice
blackmun
delivered
opinion
internal
revenue
code
social
security
act
direct
secretary
treasury
intercept
certain
tax
refunds
payable
persons
failed
meet
obligations
case
appeals
ninth
circuit
ruled
payments
involving
credits
intercepted
granted
certiorari
ruling
conflict
decisions
courts
appeals
second
tenth
circuits
see
rucker
secretary
treasury
nelson
regan
cert
denied
sub
nom
manning
nelson
stanley
sorenson
husband
petitioner
marie
sorenson
legally
obligated
make
payments
child
previous
marriage
custody
former
wife
sorenson
unemployed
disability
fell
behind
support
payments
former
wife
applied
welfare
benefits
state
washington
since
program
aid
families
dependent
children
afdc
required
condition
eligibility
applicants
welfare
assign
state
concerned
right
payments
accrued
time
assignment
pub
stat
thus
stanley
sorenson
former
wife
turned
state
right
collect
payments
sorenson
failed
make
stanley
marie
sorenson
also
dependent
child
living
thus
potentially
eligible
receive
credit
calendar
year
time
relevant
lawsuit
internal
revenue
code
amended
provided
individual
responsible
support
child
living
allowed
credit
tax
imposed
taxable
year
amount
equal
percent
much
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income
taxable
year
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amount
taxpayer
earned
income
increased
amount
credit
decreased
reaching
zero
taxpayer
adjusted
gross
income
reached
unlike
certain
credits
used
offset
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owed
credit
refundable
thus
individual
credit
exceeds
tax
liability
excess
amount
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tax
read
code
subject
specified
setoffs
directs
secretary
credit
refund
overpayment
person
made
individual
entitled
credit
exceeds
amount
tax
owes
thereby
receives
difference
overpaid
tax
amount
february
petitioner
husband
timely
filed
joint
federal
income
tax
return
calendar
year
petitioner
worked
part
year
sorenson
family
income
year
attributable
wages
unemployment
compensation
benefits
return
filed
sorensons
anticipated
refund
consisting
part
excess
withholding
petitioner
wages
part
credit
internal
revenue
service
however
notified
sorensons
anticipated
refund
retained
authority
granted
law
paid
state
washington
state
assigned
right
collect
sorenson
unpaid
obligations
see
second
declaration
peter
greenfield
exh
sorenson
secretary
treasury
wd
law
essentially
directs
secretary
give
priority
state
claim
recoupment
welfare
payments
made
family
failed
receive
child
support
see
social
security
act
amended
individual
claim
refund
tax
overpayment
see
amended
code
intercept
law
originally
enacted
part
omnibus
budget
reconciliation
act
obra
pub
stat
first
obra
added
social
security
act
section
directs
secretaries
treasury
health
human
services
establish
scheme
state
notify
secretary
treasury
persons
owe
payments
assigned
directs
secretary
treasury
intercept
payments
otherwise
paid
persons
upon
receiving
notice
state
agency
administering
afdc
plan
named
individual
owes
support
assigned
state
pursuant
section
secretary
treasury
shall
determine
whether
amounts
refunds
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taxes
paid
payable
individual
regardless
whether
individual
filed
tax
return
married
unmarried
individual
secretary
treasury
finds
amount
payable
shall
withhold
refunds
amount
equal
support
pay
amount
state
agency
together
notice
individual
home
address
distribution
accordance
section
amount
overpayment
refunded
person
making
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shall
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amount
support
defined
section
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security
act
owed
person
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notified
state
accordance
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security
act
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shall
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support
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person
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much
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paid
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subsection
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person
future
liability
internal
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tax
negotiations
concerning
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community
property
washington
issues
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question
presented
secretary
ultimately
withheld
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increment
sorensons
claimed
petitioner
filed
class
action
district
western
district
washington
seeking
among
things
declaration
social
security
act
reach
refund
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excess
credit
district
rejected
secretary
jurisdictional
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renewed
appeal
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pressed
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brief
respondents
agreed
secretary
arguments
merits
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judgment
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supp
appeals
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petitioner
statutory
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held
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taxes
paid
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emphasis
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congress
used
broad
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amounts
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law
gave
indication
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exclude
credit
payments
terms
appeals
also
rejected
petitioner
argument
secretary
position
conflicted
congress
intention
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benefits
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credit
first
legislative
history
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credit
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rather
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security
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sum
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like
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collection
process
see
second
congress
intended
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credit
payments
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instead
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process
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face
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statutory
mandate
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appeals
conclude
free
speculate
congress
intended
otherwise
ii
petitioner
advances
two
arguments
support
claim
excess
credit
intercepted
first
claims
language
structure
interlocking
statutory
provisions
make
intercept
law
exclude
credit
reach
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credits
neither
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taxes
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items
subject
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second
claims
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frustrate
congress
aims
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credit
thus
congress
intended
intercept
law
reach
credits
find
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persuasive
internal
revenue
code
treatment
credits
supports
government
position
individual
receive
amount
entitlement
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exceeds
tax
liability
code
defines
amount
overpayment
provides
mechanism
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overpayments
namely
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tax
refund
process
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credit
thus
inseparable
classification
overpayment
tax
petitioner
therefore
acknowledges
excess
credit
overpayment
purposes
general
provision
authorizes
tax
refunds
see
supra
secretary
lack
authorization
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claims
however
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amount
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enskilda
bank
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atlantic
cleaners
dyers
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two
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rucker
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justification
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tenth
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rucker
secretary
treasury
nelson
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social
security
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iv
part
child
support
internal
revenue
code
concern
chapter
subchapter
treatment
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rucker
secretary
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budget
reconciliation
act
state
governments
claims
recoupment
welfare
payments
made
families
unable
enforce
departed
parent
obligations
thus
real
adversaries
case
sorensons
family
one
hand
state
washington
ultimately
receive
intercepted
refund
holding
question
whether
congress
intended
divert
federal
funds
original
beneficiaries
earned
income
credit
program
treasuries
state
governments
notwithstanding
careful
admittedly
accurate
parsing
language
statute
persuaded
congress
intent
confidently
asserts
defies
belief
congress
unaware
impact
intercept
program
upon
earned
income
credit
program
enacted
obra
see
ante
pause
tell
us
congress
even
mention
important
change
point
legislative
history
obra
due
respect
hardworking
neighbors
congress
think
defies
belief
assume
substantial
number
legislators
sufficiently
familiar
obra
realize
somewhere
vast
piece
hurriedly
enacted
legislation
provision
changed
earned
income
credit
program
agree
reading
statutory
language
faithful
grammar
persuaded
however
actually
reflects
intent
congress
enacted
obra
therefore
accept
construction
relevant
statutes
adopted
courts
appeals
second
tenth
circuits
see
rucker
secretary
treasury
nelson
regan
cert
denied
sub
nom
manning
nelson
respectfully
dissent
cong
rec
remarks
long
smoking
big
cigar
speaker
house
representatives
got
angry
quality
bill
became
omnibus
budget
reconciliation
act
parts
photocopied
memorandums
parts
handwritten
last
minute
final
sections
hastily
crossed
whorls
pencil
marks
smiled
noting
cryptic
accidental
entries
bill
name
phone
number
ruth
seymour
standing
alone
special
appropriation
item
times
july