Jacobs v. Gromatsky

The basic claim advanced by appellant is that the tax collection scheme embodied in certain sections of the Internal Revenue Code [i. e,, 26 U.S.C. §§ 6015, 6511 & 6513] relating to withholding taxes and quarterly declarations of estimated income tax is unconstitutional because of its failure to provide for the payment of interest on all amounts of such withholding and estimated tax payments which are later refunded as over-payments. As adjuncts of this claim, he asserts that the court below erred in refusing to request the convening of a three-judge court pursuant to 28 U.S.C. §§ 2282 & 2284…