Revolution Cotton Mills v. United States

LITTLETON, Judge.

The question in this ease is whether the allowance of interest upon the overpayment for 1920, applied as a credit against the additional assessments for 1917,1918, and 1919, is governed by the provisions of section 1324 of the Revenue Act of 1921 or by section 1019 of the Revenue Act of 1924, and this issue turns upon the question whether a credit is allowed within the meaning of these acts when the Comihissioner signs, the schedule of overassessments for transmission to the collector or when the collector returns the schedule of overassessments and the schedule of refunds…