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NOTES 319 Tax Lawyer, Vol. 55, No. 1 NOTE THE IRS GETS ITS MONEY WHEN YOU DO: FICA AND FUTA TAXATION IN UNITED STATES V. CLEVELAND INDIANS BASEBALL CO. In United States v. Cleveland Indians Baseball Co.,1 the Supreme Court resollve a split in the circuits regarding the proper allocation of back wages with respect to the payment of Federal Insurance Contribution Act (FICA) and Federra Unemployment Tax Act (FUTA) taxes.2 Allocation of back wages to either the year in which they were earned or the...