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CHILDREN'S HOSPITAL NATIONAL MEDICAL CENTER v. UNITED STATES

Civ. A. No. 85-2086.

651 F.Supp. 712 (1986)

CHILDREN'S HOSPITAL NATIONAL MEDICAL CENTER, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, District of Columbia.

November 25, 1986.

Attorney(s) appearing for the Case

Brian R. Zapp, Wilkinson & Zapp, Hyattsville, Md., for plaintiff.

Edward J. Snyder, Michael J. Kearns, Asst. U.S. Attys., District of Columbia, Tax Div., Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM

SPORKIN, District Judge.

This case is before me on cross-motions for summary judgment. At issue is whether the plaintiff, a not-for-profit hospital, is entitled to a refund of a certain portion of Federal Insurance Contributions Act ("FICA"), 26 U.S.C. § 3101 et seq., taxes paid on behalf of itself and certain of its employees for the years 1980 and 1981.

The claim for refund arises out of employment taxes paid in connection...

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