American Viscose Corporation v. Com'r of Int. Rev.

BUFFINGTON, Circuit Judge.

In 1926 the government refunded to the taxpayer $3,896,663.14 income and profit taxes illegally assessed and collected for the years 1917-1919. This sum, together with $1,409,-856.46 interest, was paid to the taxpayer in 1926. Thereupon the question here involved arose, namely, whether interest paid by the United States in 1926, pursuant to section 1116 of the Revenue act of 1926 (26 USCA § 153 note) on money refunded as overpayments of federal income and profits taxes, is interest upon “obligations of the United States,” and therefore exempt from tax under section…