Chester C. Fosgate Co. v. United States

SIBLEY, Circuit Judge.

The question presented by this appeal and cross-appeal is whether certain services of the employees of the Chester C. Fosgate Company were, as the law stood in 1937, excepted from the basis for Social Security taxes for that year as being “agricultural labor.”

The Company had a processing and packing plant in Florida for citrus fruits, in which it had invested over a quarter of a million • dollars, and through which it handled and marketed over a half million boxes of fruit per year. It had some groves of its own and leased other groves which it cultivated, processing and…