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SINGER COMPANY v. UNITED STATES

No. 344-64.

449 F.2d 413 (1971)

The SINGER COMPANY v. The UNITED STATES.

United States Court of Claims.

October 15, 1971.

Attorney(s) appearing for the Case

John J. Boland, New York City, attorney of record, for plaintiff. William W. Karatz and Hugh M. Dougan, New York City, of counsel.

Theodore Peyser, Jr., Washington, D. C., with whom was Asst. Atty. Gen. Johnnie M. Walters, for defendant. Philip R. Miller, Washington, D. C., of counsel.

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

OPINION*

LARAMORE, Judge.

This is an action to recover alleged overpayments of Federal income taxes paid by plaintiff for the tax year of 1954. The amount in controversy involves a refund of $510,762.73, plus statutory interest on the amount of recovery. The determination of whether or not plaintiff is entitled to recover said amount is based on sections 170 and 162(b)1 and whether, pursuant to section...

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