United States v. Northwestern Mutual Insurance Co., a Washington Corporation

MERRILL, Circuit Judge.

The United States appeals from a judgment of the district court granting taxpayer a refund of interest assessed on its income tax.

The interest had been assessed upon refunds of foreign tax which had been paid by the taxpayer and as to which it had previously taken federal income tax credit. The question presented by the appeal is as to the date from which interest on these deficiencies shall run. At issue is the sum of $2,468.11 assessed by the Washington District Director for the year 1955 and the sum of $300.48 assessed for 1957.

The assessments were made pursuant to…