cms estate vs sss- cms questions whether or not it is covered by sss for its logging business when it only

applied for real estate business when cms tried to refund the payment for the coverage that it remitted
to sss for its logging business and sss refused stating that cms was already under the coverage of sss
when it started its real estate business in 12-1-1952 and 4-1-1957 for its logging business. sc stated that
cms is already subject to compulsory coverage since it started its real estate business and its logging
business is included already in that coverage since the intent of the legislature in the social security act is
to cover as many people as possible. sss funds are not subject to tax since it is for the members and their
benefits. it is the employer which is subject to sss coverage not the business and he may compelled to
apply to sss when he is in operation for 2 years and has 6 employees.