American Woolen Co. v. United States

GREEN, Judge.

A rehearing having been granted, the contentions made in argument by plaintiff seem to us so much broader than were originally made as to require some further statements as to the position of the court

The court cannot agree with counsel for plaintiff in the narrow construction which they give to the statutory definition of a deficiency. A “deficiency” is defined in section 273 of the Revenue Act of 1926, 44 Stat. 55, as “the amount by which the tax imposed by this title exceeds the amount shown as the tax by the taxpayer upon his return,” increased and diminished as further…