The Jewel Shop, Inc. v. The United States

LARAMORE, Judge.

This ease comes to us on stipulated facts which plaintiff claims make out a good cause of action for the recovery of interest allegedly due on income tax over- payments. On June 18, 1951, the Commissioner of Internal Revenue made a jeopardy assessment against The Jewel Shop, Inc., a South Carolina corporation, of additional income and excess profits taxes including fraud and delinquency penalties and interest for the taxable years 1944 through 1950. Plaintiff paid only part of the alleged deficiencies. On July 13, 1956, the Commissioner assessed plaintiff for deficiencies in…