JOHN P. MOORE, Circuit Judge.
This is a cross-appeal in an action for refund of FICA taxes. Taxpayer, Hoerl & Associates, is a professional corporation wholly owned by Richard and Jean Hoerl who are its only employees. Taxpayer executed contracts with the Hoerls under which each was to be paid a biannual salary, but the agreements did not state when or how the compensation was to be paid. In practice, each employee was paid for two years' services in one year...
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