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IN RE QUALITY STORES, INC.

Bankruptcy No. GG 01-10662, Adversary No. 05-80573.

383 B.R. 67 (2008)

In re QUALITY STORES, INC., et al., Debtors. Quality Stores, Inc., et al., Plaintiffs, v. United States of America, Defendant.

United States Bankruptcy Court, W.D. Michigan.

March 3, 2008.

Attorney(s) appearing for the Case

Natalie Hoyer Keller, Kirkland & Ellis, LLP, Chicago, IL, for Quality Stores, Inc., et al.

Michael W. Davis, U.S. Department of Justice, Washington, D.C., for United States of America.

OPINION REGARDING SEVERANCE PAY AND FICA CONTRIBUTIONS

JAMES D. GREGG, Chief Judge.

I. INTRODUCTION

Employees of Quality Stores, Inc., et al. ("Debtors") received severance pay resulting from their involuntary termination from employment because of business cessation. The money received, without question, constitutes "income" within the meaning of the Internal Revenue Code. The question is...

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