Royal Bank of Canada v. United States

LITTLETON, Judge.

Upon motion of defendant a new trial was granted in this ease and the original findings of fact and opinion published June 3, 1929, were vacated and set aside.

Plaintiff contends that it is entitled to recover the entire overpayment of $70,262.45 for the fiscal year 1918 plus interest because the commissioner rejected its claim for refund and claim for credit, although the amount of the overpayment was used to satisfy and discharge its liability for the additional assessment of $41,497.24 for the fiscal year 1917 and $28,765.21 of its tax assessed and due for the fiscal year…