Silver v. United States

BRENNAN, Chief Judge.

The trial of this non-jury tax refund case leaves two questions for decision. (1) The legality of the assessment and collection of interest upon the amount of a jeopardy tax assessment which included an item of interest computed to the date *2of such assessment. The collection of interest upon interest is the crux of this question. (2) The legal propriety of the assessment and collection of interest upon a part of the tax unpaid after the date when the taxpayers’ claim that a partial payment of said tax was made available to the taxing authority.

No question is raised as to…