Trans-Serve, Inc. v. United States

WIENER, Circuit Judge:

Plaintiff-Appellant Trans-Serve, Inc. (“Trans-Serve”) disputes the amount of federal employment taxes that it owes for tax years 1987 through 1996. Trans-Serve contends that it owes only the ordinary federal employment taxes required by the Federal Insurance Contributions Act (“FICA”) 1 and Federal Unemployment Tax Act (“FUTA”). 2 The government counters that, as the district court held, Trans-Serve owes such taxes at the higher rates required by the Railroad Retirement Tax Act (“RRTA”) 3 and Railroad Unemployment Repayment Tax Act (“RURTA”) 4 (the “Railroad Acts”). We…