Bardahl Manufacturing Corporation v. United States

The taxpayer appeals from a judgment of the district court rejecting its claim for refund of $51,946.29 in interest on deficiencies in the payment of accumulated earnings tax imposed under section 531 of the Internal Revenue Code of 1954 in respect of the taxable years 1956 through 1959.

The district court held, in accordance with the Government’s contention, that interest on the deficiencies accrued from the due date of the taxpayer’s federal returns, following the general rule prescribed by section 6601(a) of the 1954 Code. 1 It rejected the taxpayer’s argu ment that interest accrued from…