Martin-Marietta Corporation v. The United States

OPINION

LARAMORE, Judge.

This is an action to recover additional statutory interest in the amount of $1,-825,585.59 for the years 1954 and 1955, and assessed interest in the amount of $23,780.10 for the year 1954. The issues presented involve the extent to which section 1481 of the Internal Revenue Code of 19541 is applicable to the instant case, and the dates at which over-payments of corporate income taxes, within the meaning of section 6611(a) and (b), occurred for the years in question. The facts are as stipulated and will be recited here only to the extent necessary to explain the basis…