Riverside & Dan River Cotton Mills, Inc. v. United States

LITTLETON, Judge.

Plaintiff seeks to recover $115,913.77 as interest on $391,402.47, overpayment of tax for 1920 which was applied as a credit against an additional tax for 1918 assessed on November 6, 1926. It contends that under section 1116 of the Revenue Aet of 1926 the amount of $391,402.47 for 1918, against which a portion of the overpayment for 1920 was credited, was an additional assessment made under the 1926 aet and that, therefore, interest should be computed from the date of the overpayment in December, 1921, to the date of the additional assessment on November 6, 1926; that the…