Legal Opinion
Time, Inc. v. United States
District Court, S.D. New York
Decided February 19, 1964PublishedCited by 9 opinions
1Opinion of the Court
LEVET, District Judge.
The plaintiff-taxpayer, Time, Inc., seeks by this tax refund action to recover $61,451.40 assessed by the Commissioner as interest on an income tax deficiency of the taxpayer for the year 1944. Time paid the interest assessed and preserved *681its right to recover the amount by the timely filing of claims for refund. Both the plaintiff and defendant move for summary judgment.
The entire dispute centers about the date on which interest was to commence. The Commissioner, relying upon the second parenthetical exception of Section 292(b),1 assessed interest on $683,313 2 of an…
2Cases cited10 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- United States v. ChildsSupreme Court of the United States · 1924
- United States v. Koppers Co.Supreme Court of the United States · 1955
- United States v. ZacksSupreme Court of the United States · 1963
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Avon Products, Inc. v. United StatesCourt of Appeals for the Second Circuit · 1978
- Kyle A. Vick, Jr., in His Capacity as Independent of the Estate of Lucille M. Hooper, Deceased v. Robert L. PhinneyCourt of Appeals for the Fifth Circuit · 1969
- United States v. AugspurgerDistrict Court, W.D. New York · 1981
- Universal Pictures Company, Inc. v. United StatesCourt of Appeals for the Second Circuit · 1965
4 more not listed; retrieve them via the Exa API.