Union Pac. R. Co. v. Bowers

*790AUGUSTUS N. HAND, Circuit Judge

(after stating the facts as above). There is little, if anything, to be added to the opinion of the court below. The plaintiff contends that the statute only contemplated interest upon a deficiency of income tax payments which existed at the time of the examination and audit of the returns by the Commissioner, and says that at the time of such examination the tax had been paid in full, so that there was no deficiency, and could, therefore, be no interest due.

The language of the section applicable is:

“As soon as practicable after the return is filed, the…