OPINION OF THE COURT
ROSENN, Circuit Judge.
This appeal presents the narrow but difficult question of whether taxpayers are exempt from Federal Insurance Contributions Act (FICA) taxation on amounts paid prior to January 1, 1984, pursuant to salary reduction agreements, for the purchase of retirement annuities qualifying for income tax deferral. The issue arises in connection with a refund suit instituted by the taxpayer, Temple University, to recover $690...
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