Mann v. United States

LITTLETON, Judge.

The first contention of plaintiff is that the Commissioner of Internal Revenue proceeded in an unlawful manner and contrary to the provisions of section 250(d) of the Revenue Acts of 1918 and 1921 (40 Stat. 1083; 42 Stat. 265) in determining the tax liability for the fiscal year ended January 31,1919, in that he did not give plaintiff notice or an opportunity to be heard; that the application by the Commissioner of a portion of the total tax paid on the calendar year 1919 return in satisfaction of the total tax liability determined by him to be due for said fiscal year ending…