SHIP CABIN CLUB v. CRENSHAW

No. 6470.

199 F.2d 594 (1952)

SHIP CABIN CLUB, Inc. v. CRENSHAW, Collector of Internal Revenue.

United States Court of Appeals Fourth Circuit.

Decided November 5, 1952.


Attorney(s) appearing for the Case

Jordan A. Pugh, III, Norfolk, Va., for appellant.

Robert B. Ross, Sp. Asst. to the Atty. Gen. (Charles S. Lyon, Acting Asst. Atty. Gen., Ellis N. Slack, Helen Goodner and Maryhelen Wigle, Sp. Assts. to the Atty. Gen., A. Carter Whitehead, U. S. Atty., Richmond, Va., and Charles R. Dalton, Jr., Asst. U. S. Atty., Norfolk, Va., on brief), for appellee.

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


SOPER, Circuit Judge.

Ship Cabin Club, Inc., a Virginia corporation, brought this suit to recover the sum of $2110 paid by the corporation under protest to the Collector of Internal Revenue on account of a penalty assessed against it for failing to collect and pay over to the Collector the tax on dues or assessments paid to it by its stockholders or members.

Section 1710 of the Internal Revenue Code imposes a tax of 20 per centum of any amount paid as dues...

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