Alan Horowitz was quoted regarding the Jan. 4 decision by the U.S. Court of Appeals for the Sixth Circuit to deny the government's petition for rehearing of the court's decision that supplemental unemployment benefit (SUB) payments are not subject to Federal Insurance Contributions Act taxes (United States v. Quality Stores Inc.).  According to Horowitz, the case, which centers on whether severance payments are to be treated as "wages" for purposes of FICA taxation, is a likely candidate for a request for Supreme Court review. "Given the conflict and the apparent importance of having a uniform nationwide rule, there is a significant possibility that the government will ask the Supreme Court to step in," Horowitz said.