Algodon Manufacturing Company, Inc. v. Edwin Gill, Formerly Collector of Internal Revenue

SOBELOFF, Circuit Judge.

Algodon Manufacturing Company reached an agreement with the Commissioner of Internal Revenue as to the principal sum of the tax deficiency due by it, but because of the manner in which the settlement negotiations were conducted, a controversy developed concerning the computation of interest on that deficiency.

The taxpayer sued to recover the interest which it claims was erroneously and illegally collected from it: $7308.69 and $784.48, accruing upon tax deficiencies determined for its fiscal years 1944 and 1945, respectively. The taxpayer claims that under the law,…