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REVOLUTION COTTON MILLS v. UNITED STATES

No. F-152.

41 F.2d 898 (1930)

REVOLUTION COTTON MILLS v. UNITED STATES.

Court of Claims.

June 16, 1930.

Attorney(s) appearing for the Case

Ferdinand Tannenbaum, of New York City (Mark Eisner, of New York City, on the brief), for plaintiff.

Charles R. Pollard, of Washington, D. C., and Herman J. Galloway, Asst. Atty. Gen. (Ralph E. Smith, of Washington, D. C., on the brief), for the United States.

Argued before BOOTH, Chief Justice, and WILLIAMS, GREEN, and LITTLETON, Judges.

LITTLETON, Judge.

The question in this case is whether the allowance of interest upon the overpayment for 1920, applied as a credit against the additional assessments for 1917, 1918, and 1919, is governed by the provisions of section 1324 of the Revenue Act of 1921 or by section 1019 of the Revenue Act of 1924, and this issue turns upon the question whether a credit is allowed within the meaning of these acts when the Commissioner signs the schedule of overassessments...

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