No. 96-16768.

140 F.3d 1245 (1998)

ATLAS HOTELS, INC.; BW/IP International; C & R Clothiers, Inc.; California Pacific Medical Center; Chronical Publishing Company; Claris Corporation; Ensr Corporation; First Capital Life Insurance Company; Kemper Securities, Inc.; National Data Corporation; Springfield Sugar & Products, Inc.; Stanford Health Services; Sun Microsystems, Inc.; Sunbelt Beverage Corporation; William Marsh Rice University, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 6, 1998.

Attorney(s) appearing for the Case

Tommy A. Conner, San Francisco, CA, for plaintiffs-appellants.

Pamela C. Berry, Tax Division, Department of Justice, Washington, DC, for defendant-appellee.

Before: SCHROEDER, BEEZER, and BRUNETTI, Circuit Judges.

BRUNETTI, Circuit Judge:

Appellants, Sunbelt Beverage Corporation and other companies that had contracted with Hamilton Taft and Company to perform payroll tax services, appeal the district court's grant of summary judgment for the United States in the appellants' action seeking a refund of late payment penalties and interest paid by Hamilton Taft to the Internal Revenue Service pursuant to 26 U.S.C. § 6656. The district...

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