Pearson v. United States

LITTLETON, Judge.

The only question in this case is whether section 325 of the Revenue Act of 1926 (44 Stat. 87) is applicable to the overpayment of $321,933.63 in respect of tax paid by the estate of Frederick F; Ayer. That section provides as follows : “Any tax that has been paid under the provisions of Title III of the Revenue Act of 1924 prior to the enactment of this Act in excess of the tax imposed by such title as amended *1019by this Act shall be refunded without interest”

June 8, 1925, the estate of Ayer filed a return showing an estate tax of $2,370,-953.38 computed in accordance with the…