Ætna Life Ins. v. Eaton

BURROWS, District Judge.

This is an action at law to recover $376,-340.36, assessed by the government against the plaintiff for taxes for the calendar years 1923 and 1924 on federal, state, and municipal bonds, and paid by the plaintiff to the government under the provisions of section •245(a) (2) of the Revenue Acts of 1921 and Revenue Act 1924, 26 USCA § 1004(a) (2).

In 1927, when it was finally agreed between the parties as to the taxes to which the 'defendant was entitled for those years (and the year 1922, with which we are not here concerned), the parties made a “closing agreement” under…