Holmes Mfg. Co. v. United States

GREEN, Judge.

This suit is begun to recover $1,600.95, representing part of an overpayment of income and profits taxes for 1917 which had been credited to deficiencies in the taxes for the years 1915 and 1916, more than five years after the original returns for those years had been filed. The petition in the case was not filed within the period prescribed for the commencement of suits to obtain a refund of taxes, but plaintiff bases its ease upon the theory that the so-called “certificate of overassessment” which it received about November 11, 1925, constituted an account stated, or at least…