Technical Advice Memorandum - IRC Section 3306 Issue TAM Number Whether payments made by the taxpayer under the Job Training Partnership Act (JTPA), 29 U.S.C. section 1501-1781 (1982 & Supp. lll 1985), to its members for the performance of services are subject to the provisions of the Federal Unemployment Tax Act (FUTA). TAM-8748004 PDF 8/27/1987 Whether the Band is an instrumentality and wholly owned by the U.S. and, therefore, services performed for it are exempt under the Employment Security Law of the state. TAM-5910292710A PDF 10/29/1959