Columbia Gas System, Inc. v. United States

OPINION

BRUGGINK, Judge.

This is an action brought pursuant to the Tucker Act. 28 U.S.C. § 1491 (1988).1 Plaintiff seeks interest on tax refunds paid more than forty days after filing applications for tentative carryback adjustment. The Government concedes that the refund for 1982 was untimely but contends that the Internal Revenue Service (“IRS” or “Service”) made the refunds for 1980 and 1984 before any obligation to pay interest on them arose.2 Trial was held on May 9, 1994. After post-trial argument and briefing, the court concludes that interest is due with respect to all three taxable…