Pottstown Iron Co. v. United States

United States v. Swift & Company, ante, p. 468, controls the decision of this case.

Here the Commissioner of Internal Revenue, upon audit of petitioner’s income and excess-profits tax return for 1918, found an overpayment, and at the same time found an underpayment of similar taxes for the, years 1916 and 1917. On January 22, 1926, he made, additional .assessments of the underpayments for 1916 and 1917; and on January 29 he approved a schedule of overassess-ments which embraced the overpayment for the year 1918. The schedule was transmitted to the Collector of the. appropriate district with…