The board of directors of Necanicum Investment Co., a property management corporation in Oregon, meets on a regular basis. Necanicum paid the directors $6,000 each in the third quarter of 2003. It did not report the payments as part of its payroll and did not pay unemployment tax on the payments. The Oregon Employment Department contended that the company owed $700 in unemployment taxes on the payments to the directors. Necanicum protested. The administrative law judge (ALJ) for the Employment Department held that the company owed the taxes because directors’ fees are the same as wages for unemployment tax purposes. Necanicum appealed, but the court of appeals affirmed the ALJ’s ruling. The company appealed again. Are payments to directors the same as wages for tax purposes? Why or why not? [Necanicum Investment Co. v. Employment Department, 345 Or. 138, 190 P.3d 368 (2008)]