P. Lorillard Company v. United States

In 1959 the taxpayer, which elected to pay its tax in two installments, applied on Form 7004 for an extension of time to file its return. On the form the taxpayer (1) estimated its tentative tax at less than it proved later to be, and (2) paid an amount that, together with payments previously made on estimated tax, equal-led more than half of the tentative tax reported on the form and more than half of the tax which finally was computed to be due. The Commissioner assessed interest on the difference between the tax due and the tentative tax reported on Form 7004. The issue in the case is…