Estate of Plumb v. United States

*298I disagree with the major holding1 for four reasons: (1) on its face the statutory language (denying interest) is clearly against taxpayer; (2) the legislative history is inconclusive at best; (3) this court has already held that we should apply the "unqualified” wording of the statute, leaving it to Congress to change any undesirable aspects of the existing legislation; and (4) no previous decision of this court calls for the majority’s result.

1. Section 2011(c) says flatly that "any” refund "based” on the state tax credit "shall be made without interest.” I.R.C. § 2011(c). There are no…