Appoloni v. United States
District Court, W.D. Michigan
1Opinion of the Court
OPINION
QUIST, District Judge.
I. Background
Plaintiffs, Donald F. Appoloni, Sr., Russell C. Bergemann, and Sandra Engel, are retired public school teachers who allege that they exchanged their property rights of tenure and contractual rights of just cause employment for payments of money by their respective employers. Plaintiffs’ employers withheld taxes on those payments under the Federal Insurance Contributions Act (“FICA”). Between January 16, 2002, and September 27, 2002, Plaintiffs filed claims for refunds for the FICA tax withheld on the payments they received in exchange for their…
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