payroll tax

The Social Security Act imposes upon every employer 'an excise tax, with respect to having individuals in his employ.' This excise has been represented as one levied 'upon the relation of employment' and upon 'the right to employ' and as a payroll tax. It is not—as taxes upon the privilege of selling, manufacturing or processing characteristically are—measured by the value of the privilege taxed, or by either quantity or price of what is manufactured, processed or sold. A tax on the processing or sale of an article, while an excise, commonly would be denoted a tax 'on' the article processed or sold. A tax 'on' the relationship of employer-employee characterized as a tax on payrolls—is not of the type treated by the contract as a tax 'on' the goods or articles sold.