Riddell

Both parties in this case — namely, Century Indemnity Company (hereinafter called Century) and Robert A. Riddell, District Director of Internal Revenue for the Los Angeles District of California (hereinafter called Director) —have appealed from portions of a judgment involving federal income withholding taxes on wages for the period between December 7, 1953, and September 17, 1954. The decision below being oral, is unreported.

Century, the surety on the bond of a subcontractor White-Ahlgren Co., Inc. (hereinafter called White-Ahlgren or the subcontractor) was assessed by the Director for federal withholding taxes as an alleged “employer” under certain provisions of the Internal Revenue Code of 1939, as enacted by the Current Tax Payment Act of 1943, and as further amended, 1 and the applicable Treasury Regulations.

Century paid the assessments under protest, and brought this action for refund thereof.

*683 The case below also involved claims for refund of certain other sums paid under protest by Century on the Director’s claim of liability for taxes under the Federal Insurance Contributions Act, and the Federal Unemployment Taxes *684 Act, which claims were decided below…