Sheet Metal Workers Local 141 Supplemental Unemployment Benefit Trust Fund v. United States of America, Internal Revenue Service

WELLFORD, Circuit Judge.

We are presented with a tax refund case that raises a question of first impression in this circuit: whether payments to employee-beneficiaries derived from the liquidation of a supplemental unemployment benefit trust fund are “wages” within the meaning of the Federal Insurance Contributions Act (“FICA”) and the Federal Unemployment Tax Act (“FUTA”). The district court concluded that the payments in this ease were not wages. For the reasons stated, we REVERSE.

I

The relevant facts involve little, if any, dispute. In 1975, Sheet Metal Workers Local No. 141 (“Local 141”)…