United States v. Magnolia Petroleum Co.

Respondent was assessed and paid for 1916 an income tax of $105,571.95 and for 1917, income and excess profits taxes of $1,131,076.86 in excess of the amounts for which it was liable. October 11, 1923, the Commissioner of Internal Revenue so determined and, November 22, 1923, the respondent received certificates showing such overassessments and Treasury warrants for the return of these amounts. Each certificate included a statement that “interest status will be determined as soon as necessary data can be assembled.”

Section 1324(a) of the Revenue Act of 1921, which was then in fotce,…