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ROYAL INDEMNITY CO. v. UNITED STATES

Nos. 8596, 8597.

120 F.2d 136 (1941)

ROYAL INDEMNITY CO. v. UNITED STATES. UNITED STATES v. ROYAL INDEMNITY CO.

Circuit Court of Appeals, Sixth Circuit.

June 4, 1941.

Attorney(s) appearing for the Case

Charles I. Dawson, and Arthur W. Grafton, both of Louisville, Ky. (Chas. I. Dawson, Arthur W. Grafton, and Woodward, Dawson & Hobson, all of Louisville, Ky., on the brief), for Royal Indemnity Co.

Paul S. McMahon, of Washington, D. C. (Samuel O. Clark, Jr., Sewall Key, Norman D. Keller, and Paul R. Russell, all of Washington, D. C., and Eli H. Brown, III, U. S. Atty., of Louisville, Ky., on the brief), for the United States.

Before HICKS, SIMONS, and MARTIN, Circuit Judges.

SIMONS, Circuit Judge.

The appeal challenges the liability imposed on the appellant as surety for the Louisville Woolen Mills under a bond filed with the Commissioner of Internal Revenue for the purpose of securing the United States in the collection of the final installment of income and excess profits tax for the year 1918.

For that year the Louisville Woolen Mills filed its individual tentative return showing taxes due from it in the amount of $129,364...

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