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STA OF BALTIMORE-ILA CONTAINER ROYALTY FUND v. U.S.

No. 86-3017.

804 F.2d 296 (1986)

STA OF BALTIMORE-ILA CONTAINER ROYALTY FUND, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided November 11, 1986.

Attorney(s) appearing for the Case

Paul B. Lang (A. Adgate Duer, Neil S. Kurlander, Niles, Barton & Wilmer, Baltimore, Md., on brief), for appellant.

Gary D. Gray, Tax Div., Dept. of Justice (Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup, Tax Div., Dept. of Justice, Wynette J. Hewett, Tax Div., Dept. of Justice, Washington, D.C., Catherine C. Blake, U.S. Atty., Baltimore, Md., on brief), for appellee.

Before HALL, CHAPMAN, and WILKINS, Circuit Judges.

K.K. HALL, Circuit Judge:

The Steamship Trade Association of Baltimore — International Longshoremen's Association Container Royalty Fund (the "Fund") appeals from an order of the district court, denying the Fund's claim for a refund of federal taxes which it paid between 1977 and 1979, pursuant to the Federal Insurance Contributions Act ("FICA"), 26 U.S.C. §§ 3101 et seq.

On appeal, the Fund contends that the payments to employees which...

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