Capital Life & Health Ins. Co. v. Bowers, Collector of Internal Revenue

SOPER, Circuit Judge.

The Insurance Company sued the Collector of Internal Revenue to recover social security taxes in the sum of $7,381.21 for the years 1943 to 1948, paid by it under protest under the Federal Insurance Contributions Act, Int. Rev. Code, §§ 1400 to 1432, 26 U.S.C.A. §§ 1400-1432; and also the sum of $3,953.70 for taxes for the years 1943 to 1947 paid by it under protest under the Federal Unemployment Tax Act, Int. Rev. Code, §§ 1600-1611, 26 U.S.C.A. §§ 1600-1611. The taxes were based upon compensation in the form of commissions paid by the taxpayer to its agents for services…