St. Louis Refrigerating & Cold Storage Co. v. United States

Plaintiff paid taxes on electrical energy under Section 616 of the Bevenue Act of 1932,1 and seeks to recover them on the *706ground that they were erroneously assessed and collected.

The facts as stipulated by the respective parties are adopted as the essential facts of this case, with some additional findings in respect to Treasury decisions and regulations.

The issue is whether plaintiff’s use of electrical energy is commercial consumption as defined in the quoted provision of the Kevenue Act.

Plaintiff asserts its business is industrial or in a field between industrial and commercial and…