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U.S. v. AMERICAN INS. CO.

No. 93-3325.

18 F.3d 1104 (1994)

UNITED STATES of America v. AMERICAN INSURANCE COMPANY, Appellant.

United States Court of Appeals, Third Circuit.

Decided March 15, 1994.

Attorney(s) appearing for the Case

Robert F. McCabe, Jr. (argued), Edward B. Lee, III, Lindsay, McCabe & Lee, Pittsburgh, PA, for appellant American Ins. Co.

Bruce R. Ellisen, Richard Farber, Edward T. Perelmuter (argued), Kevin M. Brown, Dept. of Justice, Tax Div., Washington, DC, for appellee U.S.

Before: STAPLETON, COWEN and ALITO, Circuit Judges.

OPINION OF THE COURT

COWEN, Circuit Judge.

Appellant American Insurance Company ("American") posted a surety bond guaranteeing payment of overdue tax obligations owed by the Wheeling-Pittsburgh Steel Corporation ("Wheeling-Pitt") to the United States. Upon Wheeling-Pitt's default, the United States obtained a judgment against American when it refused to honor its surety contract obligation. American concedes it is liable to the United States for interest...

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