Pitcairn Co. v. United States

Plaintiff sues to recover the interest it paid as a part of the income tax and personal holding company deficiencies assessed for the year 1952, together with interest on the amounts so paid and on the deficiency assessments for the period of time such deficiencies were held.

In March of 1953, plaintiff, a Delaware corporation, filed its income tax return for 1952, which showed a tax liability of $471,863.39. The income tax so reported and paid was the alternative tax (less foreign tax credit) provided for in section 117 (c) and was computed as follows:(1) Net income-$7,053,653.03(2) Dividends…