United States v. Factors & Finance Co.

Mr. Justice Cardozo. .delivered the opinion of the Court.

The suit is by a taxpayer to recover -<$19,995.44, with interest, an overpayment of income and profits tax. Here, as .in other cases decided at this session, the judgment stands or falls according to our determination of the time, within which a notice of a claim for refund is subject to amendment.

On June 15, 1918, respondent, a corporation, filed an income arid.profits tax return for the calendar year ending Deceriiber 31, 1917, and made payment of the tax in accordance therewith. The amount of the payment was $177,338.72. . In May,…