PEARL ASSURANCE COMPANY v. UNITED STATES

No. 211-62.

324 F.2d 512 (1963)

PEARL ASSURANCE COMPANY, Limited v. The UNITED STATES.

United States Court of Claims.

Rehearing Denied January 24, 1964.


Attorney(s) appearing for the Case

Eugene Chester, New York City, for plaintiff. Everett, Johnson & Breckinridge, New York City, were on the briefs.

Mitchell Samuelson, Washington, D. C., with whom was Asst. Atty. Gen. Louis F. Oberdorfer, for the defendant. Edward S. Smith, Lyle M. Turner, Philip R. Miller, and Earl L. Huntington, Washington, D. C., were on the brief.

Before JONES, Chief Judge, and WHITAKER, LARAMORE, DURFEE and DAVIS, Judges.


LARAMORE, Judge.

This is an action to recover additional interest on a refund of 1942 income taxes refunded in 1956.

The facts have been stipulated and briefly are as follows: On June 14, 1943, plaintiff filed its income tax return for the calendar year 1942 reporting an income tax liability of $52,004.29. This tax was duly paid. Plaintiff timely filed its income tax return for the calendar years 1943 and 1944, showing an income tax liability in the amount...

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