American Potash Co. v. United States

LITTLETON, Judge.

Counsel for the defendant contends that plaintiff is not entitled to recover either of the amounts hereinbefore mentioned as additional interest on the 1917 tax overpayment of $61,561.96 under either the interest provisions of the Revenue Act, as computed by the Commissioner of Internal Revenue, or under *719the Act of March 3, 1875, on the amount of $105,432.87, being the tax overpayment plus interest thereon duly allowed by the Commissioner. In support of this position counsel for defendant argues that the provisions of the 1928 Revenue Act wholly control the matter; that…