Standard Oil Company (New Jersey) v. United States

KAUFMAN, Circuit Judge.

This appeal raises interesting questions concerning the construction of the excess profit provisions of the 1939 Internal Revenue Code. Standard Oil Company (New Jersey) brought an action in the United States District Court for the Southern District of New York to recover $2,181,489.88 paid as interest on asserted “potential deficiencies” in its consolidated excess profits tax returns for the years 1943 and 1944. Chief Judge Ryan granted the Government’s motion for summary judgment and dismissed the complaint. From the judgment entered upon that order Standard now…