Hanna Furnace Corp. v. United States

Plaintiff’s suit is based on two grounds: (1) It alleges tliat the Commissioner, in computing the taxpayer’s liability for 1918, erroneously decreased its invested capital by deducting in prior years depreciation on certain of its blast furnaces prior to the time they.had been completed and put in operation; and (2) that no deduction was taken for depreciation on the linings of its blast furnaces in the taxable year.

The defendant defends on the ground, among others, that no claim for refund on these grounds was filed within the statutory period. The plaintiff replies to this that a general…