General Motors Corporation v. The United States

JACK R. MILLER, Circuit Judge.

Taxpayer (“GM”) originated these actions under 26 U.S.C. § 6416(b)(1)1 in the United States Court of Claims to recover manufacturers excise taxes alleged to have been improperly assessed and collected for the period January 1, 1961, through December 31, 1966, in the amount of $2,466,162 in tax and $48,935.88 in assessed interest in No. 52-71 and $5,179,840 in tax and $124,200 in assessed interest in No. 453-71, plus statutory interest. The trial judge filed a report on the merits (50 A.F.T.R.2d (P-H) 6274) on September 30, 1982, recommending a decision for the…