Brinck v. United States

MURRAY, Chief Judge.

The facts of the case have been stipulated to and the Court finds the facts as so stipulated by the parties and from said facts concludes that the taxpayer is not entitled to recover in this case.

Counsel for the government will prepare findings of fact, conclusions of law and a form of judgment, all of which shall be submitted to counsel for the plaintiff for approval as to form.

The question before the Court is whether the taxpayer is liable for interest upon interest and interest upon fraud penalties herein. Both parties contend that Section 297, of the Code, 26 U.S.C.A.…