-~ > of 1935, it is very doubtful if interest will be allowed, Mr, Zokstrand of the Bureeu of Internal Revenue hes advised that the Interpretative Division of the Chief Gounsei's Office has ruled in a similar oase that no interest would be aliowed on refunds of excise taxes for the period in which the 1932 Act was in foree and until the second month follow- ing the enactment of the Revenue Act of 1935. interest computed on the refund of principal of 910,079.95 at 334 would amount to (3,326.38, exelusive of amy interest which might be allowed on the refund of Ceficlency interest,as aforesaid, of $2,008.08, Seetion "Tn no 621 cease respect any or Section 401 (b) and (¢) 621 of the Revenues Act second month 3443 (¢) of the of interest of ‘the Revenue Act of 1935, of provides qualified at proviso statutes, ealiowed will be of thie cage, will be asserted upon (4) sales importedby the importer, with this title amending tiat;+ date of Revenue Gode makes 6% annum: Act per the of 1938," in the in latter the the provision edministrative fact other the company hand, were refund the ‘whether in settile- interest deficiency that igs not liable for any tax Growning Company of firearms effective is clearly consummated, of respetting period, Browning nor manufacturer ae * * * controversial an after sales Code the postesuilt parent the highly is on despite The gardlessof how importer.6n the it Browning Arms Gompeny made by J.M, and M.S, 1932. 1932 Revenue internal of interest the allowed * ment of be * * with respeot to any amount of under this chapter credited or refunded interpretation Aet provides:- of tax under following of the sllewanee view interest of the for In Act amount Section 4. 1932 * * © go interest shall be allowed for any period oricer to the first day of the enactment the the refunded," Seetion * of shall to eredited (6) Arms aaid the Revenue date of tae taxpayer, since it was Company was re- the neither firearms, In the suit Browning Arms Gompany contended that {5}. in 4% wes the factor or agent, under consigment agreement, There is no quesconsumiating all of the sales in question. tion but what Browning Arms Company transferred a good and vwalié title to the inventory to the parent company prior te It is recognized that the effective date of the 1932 Act. in @ humber of ceases the Gourts have not resocnized the Vali-~ éity of such sales for tax purposes. Hach oase in litigation,