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CAPITAL LIFE & HEALTH INS CO. v. BOWERS

No. 6163.

186 F.2d 943 (1951)

CAPITAL LIFE & HEALTH INS. CO. v. BOWERS, Collector of Internal Revenue.

United States Court of Appeals Fourth Circuit.

Decided January 3, 1951.

Attorney(s) appearing for the Case

G. L. B. Rivers, Charleston, S. C. (D. McK. Winter, Columbia, S. C., and Hagood, Rivers & Young, Charleston, S. C., on the brief), for appellant.

Francis W. Sams, Sp. Asst. to the Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack and A. F. Prescott, Sp. Assts. to the Atty. Gen., Ben Scott Whaley, U. S. Atty., Charleston, S. C., and Claud N. Sapp, Jr., Asst. U. S. Atty., Columbia, S. C., on the brief), for appellee.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.

SOPER, Circuit Judge.

The Insurance Company sued the Collector of Internal Revenue to recover social security taxes in the sum of $7,381.21 for the years 1943 to 1948, paid by it under protest under the Federal Insurance Contributions Act, Int. Rev. Code, §§ 1400 to 1432, 26 U.S.C.A. §§ 1400-1432; and also the sum of $3,953.70 for taxes for the years 1943 to 1947 paid by it under protest under the Federal Unemployment Tax Act, Int. Rev. Code, ...

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