Lowe Bros. Co. v. United States

The question for decision is whether the district courts of the United States have jurisdiction, under § 24 .(20) of the Judicial Code, of a suit brought against the United States to recover income and excess profits taxes in an amount in excess of $10,000 when the recovery sought is of an overpayment of taxes for one year, effected by crediting against a barred deficiency for that year an overpayment for. another year.

Petitioner 1 overpaid income and excess profits taxes for 1918. The commissioner, on May 15, 1924, signed a schedule of overpayments .by which he approved a credit as. of April…