The United States Supreme Court case, United States v. Quality Stores, Inc., et al., 2013 revolved around the issue of whether severance payments made to employees who were involuntarily terminated are taxable under Federal Insurance Contributions Act (FICA). Quality Stores had filed for bankruptcy and in the process laid off several employees providing them with severance pay. The company treated these payments as wages subject to FICA tax but later sought a refund arguing that they should be considered supplemental unemployment benefits which are not taxable under FICA. The Internal Revenue Service denied their claim leading to litigation. Initially, lower courts sided with Quality Stores stating such payments were not 'wages' hence non-taxable under FICA law; however, upon reaching the Supreme Court it was unanimously ruled that these severance payments constituted 'wages' for tax purposes thus reversing previous rulings and affirming IRS's position.

In the dissenting opinion for United States v. Quality Stores, Inc., et al., 2013, it was argued that severance payments made to employees should not be considered as wages and thus should not be subject to taxation under FICA (Federal Insurance Contributions Act). The dissenters believed that these payments were part of supplemental unemployment benefits which are distinct from regular wages. They contended that Congress intended for SUBs (supplemental unemployment benefits) to assist workers who lost their jobs due to circumstances beyond their control and therefore such benefits shouldn't fall within the ambit of taxable income under FICA. This interpretation is in line with IRS's own understanding prior to this case where they did not consider SUBs as "wages" for FICA purposes.