Andrews Steel Co. v. United States

LITTLETON, Judge.

There is no controversy with reference to the interest paid by the Commissioner upon the amounts refunded. The controversy relates to the computation of interest upon the overpayments for 1917 and 1918 credited against the tax due for other years.

The first question is as to the daté on which the Commissioner allowed the credit within the meaning of section 1324 of the Revenue Act of 1921 (42 Stat. 316). The defendant contends that the credit was allowed on August 25,1922, the date when the Commissioner first signed the schedule of overassessments for transmission to the…