Social Security refused to credit NLRB back pay as wages.

Evidence

The respondent, Joseph Nierotko, was found by the National Labor Relations Board to have been wrongfully discharged for union activity by his employer, the Ford Motor Company, and was reinstated by that Board in his employment with directios for “back pay” for the period February 2, 1937, to September 25, 1939. … The “back pay” was paid by the employer on July 18, 1941. Thereafter Nierotko requested the Social Security Board to credit him in the sum of thl “back pay” on his Old Age and Survivor’s Insurance account with the Board. In conformity with its minute of formal general action of March 27, 1942, the Board refused to credit Nierotko’s “back pay” as wages. — Henry M. Hart, Jr. and Albert M. Sacks, The Legal Process, 2650