Owens-Corning Fiberglas Corp. v. United States

Plaintiff, a corporate taxpayer, sues for interest on its overpayment of estimated tax which, at taxpayer’s election, was credited against installments of estimated tax for the succeeding tax year. The facts are before the court on stipulation of the parties, reported by our commissioner pursuant to Rule 134(b).

Although there are several years at issue here, the fact pattern is the same for each year. Plaintiff pays its tax in quarterly installments based on its estimate of liability each April 15, June 15, September 15 and December 15. Any remaining balance plaintiff estimates as due is to…