Union Pacific Railroad v. United States

*704OPINION

MARGOLIS, Judge.

The plaintiff, an accrual-basis taxpayer, brought this action to recover statutory interest in the amount of $72.8 million on overpayments of federal excess profits taxes for the years 1943 and 1944 (First and Second Claims), and on overpayments of federal income and declared value excess profits taxes for 1943, 1944, and 1945 (Third, Fourth, and Fifth Claims).1 The defendant has moved for summary judgment on the first three claims; the plaintiff has cross moved for summary judgment on all the claims. After hearing oral argument and considering the entire record, the…