Washington Irrigation & Development Co. v. United States

(concurring in part, dissenting in part) — I concur in the majority, however, I would reverse the trial court's denial of interest to the Internal Revenue Service. *304In affirming it, the majority violates the long-standing rule that a court's powers of equity do not permit it to disregard statutory directives.

The Internal Revenue Code expressly provides that: "If any amount of tax imposed by this title ... is not paid . . . interest on such amount at an annual rate established under section 6621 shall be paid ..." 26 U.S.C. § 6601(a) (1982). A long line of cases establishes that this…