Lafayette Worsted Co. v. Page

MORTON, District Judge.

The plaintiff was assessed and paid income taxes for the years 1918 and 1919. Thereafter applications for refunds were filed by it, on which about $167,000 was repaid. Later the Commissioner, having become convinced that the refund was erroneously allowed, made a “jeopardy” assessment, as it is called, of additional taxes upon the plaintiff for the same years and in the same amount as the refund. In so doing he z’elied upon the same figures and returns as those on which the original assessment was made; there was no claim of fraud, or that concealed income had been…