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JEWEL SHOP, INC. v. UNITED STATES

No. 274-61.

352 F.2d 526 (1965)

The JEWEL SHOP, INC. v. The UNITED STATES.

United States Court of Claims.

November 12, 1965.

Attorney(s) appearing for the Case

Jacquin D. Bierman, New York City, attorney of record, for plaintiff. Chase & Bierman, New York City, of counsel.

Sheldon P. Migdal, Washington, D. C., with whom was Acting Asst. Atty. Gen. Richard M. Roberts, for defendant. C. Moxley Featherston, Lyle M. Turner, and Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS and COLLINS, Judges.

LARAMORE, Judge.

This case comes to us on stipulated facts which plaintiff claims make out a good cause of action for the recovery of interest allegedly due on income tax overpayments. On June 18, 1951, the Commissioner of Internal Revenue made a jeopardy assessment against The Jewel Shop, Inc., a South Carolina corporation, of additional income and excess profits taxes including fraud and delinquency penalties and interest...

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