Sta of Baltimore-Ila Container Royalty Fund v. United States

K.K. HALL, Circuit Judge:

The Steamship Trade Association of Baltimore — International Longshoremen’s Association Container Royalty Fund (the “Fund”) appeals from an order of the district court, denying the Fund’s claim for a refund of federal taxes which it paid between 1977 and 1979, pursuant to the Federal Insurance Contributions Act (“FICA”), 26 U.S.C. §§ 3101 etseq.

On appeal, the Fund contends that the payments to employees which are at issue in this case do not constitute wages subject to taxation under FICA. Upon consideration of the record, briefs, and oral argument, we find ourselves…