Sunland Industries, Inc., a Corporation v. United States

On March 15, 1944, appellant, Sunland Industries, Inc., a California corporation, filed its excess profits tax return for 1943. The total amount of tax shown on the return was $193,238.42. Of the $193,238.42, $129,469.74 was paid and collected at the time prescribed for payment, and $63,768.68 remained unpaid until September 13, 1948. Of the $63,-768.68, $1,100.59 was paid and collected on September 13, 1948, and $62,668.09 remained unpaid until December 14, 1949. Of the $62,668.09, $58,089.75 was paid and collected on December 14, 1949, and $4,578.34 remained unpaid until November, 1950.

With the $1,100.59, interest in the sum of $217.69 was paid and collected. Thus a total of $1,318.28 was paid and collected on September 13, 1948. With the $58,-089.75, interest in the sum of $20,040.96 was paid and collected. Thus a total of $78,130.71 was paid and collected on December 14, 1949. The $1,318.28 was assessed on August 20, 1948 — 24 days before it was paid and collected. The $78,130.71 was assessed on January 3, 1950 — 19 days after it was paid and collected. All collections mentioned above were made by the Collector of Internal Revenue for the First Collection District of…