Lehigh Valley Cooperative Farmers v. Commonwealth, Bureau of Employment Security Department of Labor & Industry

OPINION

LARSEN, Justice.

The sole issue in this case is whether cooperative agricultural associations are exempt from paying unemployment compensation taxes. During the four-year period from the third quarter of 1973 to the second quarter of 1977, Lehigh Valley Cooperative Farms [hereinafter “Lehigh Valley”], a cooperative agricultural association, paid unemployment compensation taxes totaling $357,733.42. At that time, Le-high Valley believed that it was legally obligated to pay those taxes. In 1977, Lehigh Valley applied for a refund but the Bureau of Employment Security [hereinafter…