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

OPINION

JANE B. STRANCH, Circuit Judge.

This appeal arises from an adversary action filed in the bankruptcy court for the Western District of Michigan by Quality Stores, Inc., its affiliated companies, and certain employees (collectively Quality Stores) against the United States seeking a refund of $1,000,125 in taxes paid under the Federal Insurance Contributions Act (FICA). 1 On stipulated facts and cross-motions for summary judgment, the bank ruptcy court ordered a full refund, holding that payments Quality Stores made to its employees upon terminating their employment involuntarily due to…