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ALGODON MANUFACTURING COMPANY v. GILL

No. 7328.

243 F.2d 160 (1957)

ALGODON MANUFACTURING COMPANY, Inc., Appellant, v. Edwin GILL, Formerly Collector of Internal Revenue, Appellee.

United States Court of Appeals Fourth Circuit.

Decided April 1, 1957.

Attorney(s) appearing for the Case

Morris B. Abram, Atlanta, Ga. (Charles F. Wittenstein, Atlanta, Ga., on the brief), for appellant.

Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Hilbert F. Zarky, Attys., Dept. of Justice, Washington, D. C., and Edwin M. Stanley, U. S. Atty., Greensboro, N. C., on the brief), for appellee.

Before PARKER, Chief Judge, SOBELOFF, Circuit Judge, and WILLIAMS, District Judge.

SOBELOFF, Circuit Judge.

Algodon Manufacturing Company reached an agreement with the Commissioner of Internal Revenue as to the principal sum of the tax deficiency due by it, but because of the manner in which the settlement negotiations were conducted, a controversy developed concerning the computation of interest on that deficiency.

The taxpayer sued to recover the interest which it claims was erroneously and illegally collected from it: $7308.69 and $784...

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