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U.S. v. QUALITY STORES, INC.

No. 12-1408.

134 S.Ct. 1395 (2014)

188 L.Ed.2d 413

UNITED STATES, Petitioner v. QUALITY STORES, INC., et al.

Supreme Court of United States.

Decided March 25, 2014.

Attorney(s) appearing for the Case

Eric J. Feigin , Washington, DC, for Petitioner.

Robert S. Hertzberg , Southfield, MI, for Respondents.

Donald B. Verrilli, Jr. , Solicitor General, Kathryn Keneally , Assistant Attorney General, Malcolm L. Stewart , Deputy Solicitor General, Eric J. Feigin , Assistant to the Solicitor General, Kenneth L. Greene , Francesca Ugolini , Attorneys, Department of Justice, Washington, DC, for Petitioner.

Robert S. Hertzberg , Counsel of Record, Pepper Hamilton LLP, Southfield, MI, Michael H. Reed , Pepper Hamilton LLP, Philadelphia, PA, Deborah Kovsky-Apap , Lesley S. Welwarth , Pepper Hamilton LLP, Southfield, MI, for Respondents.

Justice KENNEDY delivered the opinion of the Court.

This case presents the question whether severance payments made to employees terminated against their will are taxable wages under the Federal Insurance Contributions Act (FICA), 26 U.S.C. § 3101 et seq.

The Court of Appeals for the Sixth Circuit held that the payments are not wages taxed by FICA. To reach its holding, the Court of Appeals relied not on FICA's definition of wages but on §...

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