GODFREY v. U.S.

No. 92-3061.

997 F.2d 335 (1993)

Dudley J. GODFREY, Jr. and Constance P. Godfrey, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 28, 1993.


Attorney(s) appearing for the Case

John Kirtley, Godfrey & Kahn, Milwaukee, WI (argued), for plaintiffs-appellants.

John E. Fryatt, U.S. Atty., Milwaukee, WI, Gary R. Allen, Ann Belanger Durney, S. Robert Lyons (argued), Dept. of Justice, Tax Div., Appellate Section, Tamera Fine-Trail, Dept. of Justice, Tax Div., Washington, DC, for defendant-appellee.

Before BAUER, Chief Judge, RIPPLE and KANNE, Circuit Judges.


KANNE, Circuit Judge.

Time is money. In the context of the interest a taxpayer loses while awaiting the issuance of a $279,323.00 tax refund check, four months equates to $6,580.20. Internal Revenue Code § 6611, 26 U.S.C. § 6611, recognizes this principle by providing that, in limited circumstances, taxpayers shall receive interest on the money the government holds as a result of their overpayment of taxes. In this...

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