Rev. Rul. 57-444

Under section 710(a)(5) of the Internal Revenue Code of 1939, a corporate taxpayer seeking excess profits tax relief under section 722 of the Code, was permitted, under certain conditions, to defer payment of a portion of the excess profits tax otherwise payable at the time prescribed for payment, pending a final determination with respect to its application for relief under section 722. To the extent it does not exceed the amount of the reduction in excess profits tax liability attributable to an allowance under section 722, the amount so deferred under section 710(a)(5) does not constitute a deficiency and interest shall not be assessed thereon under section 292. However, to the extent that the amount deferred under section 710(a)(5) exceeds the reduction in excess profits tax liability attributable to an allowance under section 722, interest shall be computed from the due date of the tax to the date of assessment or to the 30th day after filing a waiver of restrictions on assessment, whichever is earlier.