United States v. Quality Stores, Inc. (In Re Quality Stores, Inc.)

OPINION

JANET T. NEFF, District Judge.

This matter is before the Court on appeal from the Bankruptcy Court. Plaintiffs (“Quality Stores”) commenced this adversary proceeding against defendant United States, seeking the refund of $1,000,125 in Federal Insurance Contributions Act 1 (FICA) taxes paid with regard to severance payments to former employees. The Bankruptcy Court, the Honorable James D. Gregg, entered a final judgment in favor of plaintiffs, determining that the payments made to the employees pursuant to the severance programs were not “wages” for purposes of FICA taxation. See Quality…