Protest 98751-K of Wah Shang Co.

*174Opinion by

Ekwall, J.

From the testimony it appeared that the collector’s original liquidation was taken pursuant to the decision reported in Columbia Co. v. United States (5 Cust. Ct. 175, C. D. 395): The reliquidation was taken pursuant to instructions from the Commissioner of Customs received October 29, 1941. Inasmuch as section 514, Tariff Act of 1930, provides that liquidation in the absence of protest “upon the expiration of sixty days from the date” thereof shall be final and conclusive upon all persons, it was held that under said section the collector had no power to reliquidate after…