Legal Opinion

Universal Pictures Co. v. United States

District Court, S.D. New York

Decided April 30, 1964PublishedCited by 2 opinions

1Opinion of the Court

LEVET, District Judge.

The plaintiff-taxpayer, Universal Pictures Company, Inc., seeks by this tax refund action to recover what it alleges to be overpayments of interest on income and excess profits tax payments made by it for its fiscal years ended October 31, 1944 and 1945.1

For the year 1944, the Commissioner assessed interest in taxpayer’s favor pursuant to Section 3771(g) 2 from January 31, 1951 on a component excess profits tax overassessment resulting in part from the carryback to 1944 from 1946 of an unused excess profits credit due to the granting of taxpayer’s prior application under…

2Cases cited13 opinions

  1. Boston Sand and Gravel Co. v. United StatesSupreme Court of the United States · 1928
  2. Rosenman v. United StatesSupreme Court of the United States · 1945
  3. United States v. North American Transportation & Trading Co.Supreme Court of the United States · 1920
  4. Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
  5. United States v. Alcea Band of TillamooksSupreme Court of the United States · 1951

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3Cited by2 opinions

  1. Fleetboston Financial Corp. v. United StatesUnited States Court of Federal Claims · 2005
  2. Universal Pictures Company, Inc. v. United StatesCourt of Appeals for the Second Circuit · 1965

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