ON PLAINTIFF'S AND DEFENDANT'S MOTIONS FOR SUMMARY JUDGMENT
DAVIS, Judge.
This case has to do with a 1976 statute, Pub.L. 94-563, 90 Stat. 2655, 26 U.S.C. § 3121(k)(4) (1976), validating retroactively the payment by a non-profit organization of social security taxes for 1974-1976. Plaintiff, Hospital Data Center of S.C., Inc., is a non-profit computer service center owned by six county hospitals in South Carolina. It has been exempt from federal income...
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