Legal Opinion

Ty Saiki and George Saiki, a Partnership Doing Business Under the Trade Name and Style of International Chick Sexing Association v. United States

Court of Appeals for the Eighth Circuit

Decided August 3, 1962No. 16879_1PublishedCited by 17 opinions

1Opinion of the Court

VOGEL, Circuit Judge.

This is an appeal from a final judgment of the District Court denying taxpayers recovery of $23.13 federal employment taxes paid under the Federal Insurance Contributions Act, 26 U.S.C.A. §§ 3101-3126, as amended. The case involves particularly one Harold H. Tat-sumi claimed by the government to be an employee of the taxpayers who, in turn, allege him to be an independent contractor. The determination of which is correct resolves this case.

It is asserted by the taxpayers that this is a “pilot action”; that the government has filed deficiency notices demanding federal…

2Cases cited22 opinions

  1. Brady v. Southern Railway Co.Supreme Court of the United States · 1944
  2. Singer Manufacturing Co. v. RahnSupreme Court of the United States · 1889
  3. Radio City Music Hall Corp. v. United StatesCourt of Appeals for the Second Circuit · 1943
  4. Jones v. GoodsonCourt of Appeals for the Tenth Circuit · 1941
  5. Texas Co. v. HigginsCourt of Appeals for the Second Circuit · 1941

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3Cited by17 opinions

  1. Manouchehr and Lila M. Azad v. United StatesCourt of Appeals for the Eighth Circuit · 1968
  2. Air Terminal Cab, Inc. v. United States of America, Airway Taxi Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1973
  3. Trauma Nurses, Inc. v. Board of ReviewNew Jersey Superior Court Appellate Division · 1990
  4. American Consulting Corporation v. United StatesCourt of Appeals for the Third Circuit · 1971
  5. Site Oil Company of Missouri, Site Oil Company of Michigan, Inc., and William Vaughn v. National Labor Relations BoardCourt of Appeals for the Eighth Circuit · 1963

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