Breaux and Daigle, Inc. v. United States

DUHÉ, Circuit Judge.

Breaux and Daigle, Inc. appeals from the district court’s judgment denying its request for a tax refund and ordering it to pay social security and unemployment insurance taxes assessed by the Internal Revenue Service. We affirm.

Breaux and Daigle is a Louisiana corporation which processes and sells crab meat. Crab meat pickers work at Breaux and Daigle’s processing plant separating cooked crab meat from its shell. Prior to January 1, 1984, Breaux and Daigle treated the crab meat pickers as employees for tax purposes. However, in 1984 Breaux and Daigle supplied its crab meat…