RELIABLE LIFE INSURANCE COMPANY v. UNITED STATES

No. 71 C 573(2).

356 F.Supp. 235 (1973)

The RELIABLE LIFE INSURANCE COMPANY, a corporation, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Missouri, E. D.

February 6, 1973.


Attorney(s) appearing for the Case

Walter M. Clark, Armstrong, Teasdale, Kramer & Vaughan, St. Louis, Mo., for plaintiff.

Michael C. Durney, Tax Div., Dept. of Justice, Washington, D. C., Daniel Bartlett, Jr., U. S. Atty., St. Louis, Mo., for defendant.


MEMORANDUM OPINION AND ORDER

REGAN, District Judge.

For construction in this suit for refund of federal unemployment taxes paid for the years 1962 through 1966 are Sections 3306(c)(14) and 3306(d), 26 U.S.C.

Section 3301, 26 U.S.C., imposes a tax on every employer for each calendar year "with respect to having individuals in his employ," the tax to be based on "the total wages (as defined in Section 3306(b)) paid by him during the calendar year with...

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