General Electric Company v. The United States

OPINION

LARAMORE, Judge.

This is an action to recover $205,447.77 which plaintiff paid as interest on excess profits tax deficiencies for the taxable year 1944. In issue is the proper method of computing interest on deficiencies under section 292(a) of the Internal Revenue Code of 1939. 1 26 U.S.C. § 292(a) (1952 Ed.). 2 The facts have been stipulated.

On March 15, 1945, plaintiff filed a tentative return showing a 1944 excess profits tax of $128,000,000. Pursuant to section 56(b) (2) (A), it elected to pay this tax in four quarterly installments, the first $32,000,000 to be paid as of March 15,…