Mealey's (January 6, 2021, 2:22 PM EST) -- RICHMOND, Va. — The Fourth Circuit U.S. Court of Appeals on Jan. 4 vacated a ruling awarding a former franchisee of JTH Tax Inc., d/b/a Liberty Tax and SiempreTax+ LLC (collectively, Liberty Tax), $5,000 in nominal damages and an additional $49,465.94 in damages for unpaid rent, finding that the franchisee was not entitled to nominal damages and that the knowledge about the amount of unpaid rent did not constitute new evidence....