OPINION AND ORDER
CRABB, Chief Judge.
This is a civil action for a refund of federal employment taxes paid by American Family Mutual Insurance Company in response to a deficiency asserted by the Internal Revenue Service in the amount of $433,141.10. The deficiency arose from payments made to employees by plaintiff under benefit plans established in late 1983 that plaintiff had treated as not being "wages" for the purposes of income tax withholding and Federal...
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