Legal Opinion

Title Guarantee & Trust Co. v. Miles

District Court, D. Maryland

Decided June 18, 1919No. Nos. 470-472PublishedCited by 2 opinions

At Law. Actions by the Title Guarantee & Trust Company against Joshua W. Miles, Collector of Internal Revenue, to recover special taxes paid under protest.

1Opinion of the Court

ROSE, District Judge.

In these cases the plaintiff seeks to recover the sum paid under protest as the special tax imposed by the first paragraph of the third section of the Act of October 22, 1914 (3*8 Stat. 750, c. 331), upon the total amount of its capital, surplus, and undivided profits.

Originally the plaintiff was engaged solely in the business of examining and insuring real estate titles, and in other transactions closely associated therewith. This still constitutes the bulk of its business. A number of years ago it began to carry on a savings bank business in a small way, and this has…

2Cases cited1 opinion

  1. Fidelity Trust Co. of Baltimore v. MilesDistrict Court, D. Maryland · 1919

3Cited by2 opinions

  1. Fidelity & Deposit Co. of Md. v. United StatesSupreme Court of the United States · 1922
  2. Malley v. Old Colony Trust Co.Court of Appeals for the First Circuit · 1924

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