Provident Trust Co. v. United States

MARIS, District Judge.

The question raised in this case is whether the suit was begun within the period required by the applicable statute of limitations. The suit was for the recovery of an internal revenue tax which the plaintiffs claim to have been erroneously or illegally assessed and collected. They filed claims for the refund thereof with the Commissioner of Internal Revenue which were disallowed on February 10, 1933. The applicable statute (section 3226, R.S., as amended 26 U.S.C. §§ 1672-1673 [26 U.S. C.A. §§ 1672-1673]), provides that suits for the recovery of such taxes shall not be…