L. Loewy & Son v. Commissioner of Internal Revenue

(after stating the facts as above). The questions involved on this appeal are:(1) Whether the taxpayer and the Commissioner reached an agreement fixing the amount of the tax which, when followed by payment, constituted an accord and satisfaction, or an estoppel, and barred the assessment and collection of additional taxes.(2) Whether or not the assessment and collection of any deficiency in taxes for the fiscal years was barred by the statute of limitation.

The first question seems to have been answered by the Supreme Court in Botany Worsted Mills v. United States, 49 S. Ct. 129, 73 L. Ed.-.…