Moran v. United States

LITTLETON, Judge.

The admissible and competent evidence of record establishes that if both claims now pressed by plaintiff were allowed and the income for 1926 reduced accordingly, an additional tax of some $35,000 would remain due for 1926. However, the statute of limitation has barred collection. Cf. Lewis v. Reynolds, 284 U.S. 281, 52 S.Ct. 145, 76 L.Ed. 293. Inasmuch as the evidence of record establishes that the Wardman Corporation underpaid its tax for 1926, it is unnecessary * to discuss in detail the issues raised by plaintiff. It is sufficient to state that in our opinion the…