Memphis Cotton Oil Co. v. United States

LITTLETON, Judge.

The question in this caso is whether the Commissioner of Internal Revenue was justified in rejecting plaintiff’s claims for refund for 1922 and 1923 on the ground that they were insufficient to constitute claims under the statute, and in refusing to schedule the overassessments and allow a refund of the overpayments for the years involved, and whether, in view of such rejection, the plaintiff is entitled to maintain this suit.

We are of opinion that the Commissioner of Internal Revenue had authority under the claims as filed and the facts before him to allow the overpayments…