Universal Pictures Company, Inc. v. United States

MOORE, Circuit Judge:

These cases raise abstruse questions as to the intricacies of interest, if any, payable under the Excess Profits Tax of World War II and the corporate income tax, all under the Internal Revenue Code of 1939. Perhaps the outlines of this tax structure should be described in brief compass to make the facts more meaningful.

In the tax years in question, the excess profits tax (EPT) was computed by applying the high EPT rate to adjusted excess profits net income (AEPNI). This item in substance equalled normal tax net income (NTNI) less the excess profits credit (EPC). If EPC…