Union Pac. R. Co. v. Bowers

24 F.2d 788 (1928)

UNION PAC. R. CO.

v.

BOWERS, Collector of Internal Revenue.

No. 208.

Circuit Court of Appeals, Second Circuit.

March 12, 1928.

Before L. HAND, SWAN, and AUGUSTUS N. HAND, Circuit Judges.

AUGUSTUS N. HAND, Circuit Judge (after stating the facts as above).

There is little, if anything, to be added to the opinion of the court below. The plaintiff contends that the statute only contemplated interest upon a deficiency of income tax payments which existed at the time of the examination and audit of the returns by the Commissioner, and says that at the time of such examination the tax had…