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BESSEMER SECURITIES CORPORATION v. UNITED STATES

No. 368-61.

314 F.2d 521 (1963)

BESSEMER SECURITIES CORPORATION v. The UNITED STATES.

United States Court of Claims.

March 6, 1963.

Attorney(s) appearing for the Case

Irving H. Bull, New York City, for plaintiff. Dunnington, Bartholow & Miller, New York City, were on the brief.

George Willi, Washington, D. C., with whom was Asst. Atty. Gen. Louis F. Oberdorfer, for defendant. Lyle M. Turner and Philip R. Miller, Washington, D. C., were on the brief.

DAVIS, Judge.

The plaintiff, a personal holding company during the years here involved, seeks to recover an alleged overpayment of personal holding company surtax for 1951 in the amount of $646,417.92, together with interest. Section 500 of the Internal Revenue Code of 1939 imposes a heavy surtax, in addition to the income taxes imposed by Chapter 1, upon the undistributed subchapter A net income1 of every personal holding company. This...

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