Sta of Baltimore-Ila Container Royalty Fund v. United States

Fourth Circuit

Sta of Baltimore-Ila Container Royalty Fund v. United States

804 F.2d 296, 58 A.F.T.R.2d (RIA) 6176, 1986 U.S. App. LEXIS 33405

CourtCourt of Appeals for the Fourth Circuit

DecidedNovember 11, 1986

Docket86-3017

StatusPublished

Cited by12 cases

This text of 804 F.2d 296 (Sta of Baltimore-Ila Container Royalty Fund v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Sta of Baltimore-Ila Container Royalty Fund v. United States, 804 F.2d 296, 58 A.F.T.R.2d (RIA) 6176, 1986 U.S. App. LEXIS 33405 (4th Cir. 1986).

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Opinion

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 etseq.

On appeal, the Fund contends that the payments to employees which are at issue in this case do not constitute wages subject to taxation under FICA. Upon consideration of the record, briefs, and oral argument, we find ourselves persuaded by the thorough and sound analysis of the district court. Accordingly, we find no merit in the Fund’s appeal and affirm for the reasons expressed by the district court. STA of Baltimore — ILA Container Royalty Fund v. United States, 621 F.Supp. 1567 (D.Md. 1985).

AFFIRMED.

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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 etseq.

On appeal, the Fund contends that the payments to employees which are at issue in this case do not constitute wages subject to taxation under FICA. Upon consideration of the record, briefs, and oral argument, we find ourselves persuaded by the thorough and sound analysis of the district court. Accordingly, we find no merit in the Fund’s appeal and affirm for the reasons expressed by the district court. STA of Baltimore — ILA Container Royalty Fund v. United States, 621 F.Supp. 1567 (D.Md. 1985).

AFFIRMED.

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804 F.2d 296, 58 A.F.T.R.2d (RIA) 6176, 1986 U.S. App. LEXIS 33405, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sta-of-baltimore-ila-container-royalty-fund-v-united-states-ca4-1986.

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