Con P. Curran Printing Co. v. United States

GREEN, Judge.

The plaintiff seeks to recover an alleged overassessment and overpayment of its income and excess profit taxes for the year 1920. One of the defenses made is that these taxes were levied and collected by a special assessment made by the Commissioner under sections 327 and 328 of the Revenue Act of 1918 (40 Stat. 1093), and it is insisted that the courts are without jurisdiction to review his action.

Plaintiff made a return for the year 1920 and paid its tax accordingly. In 1925 an examination was made of plaintiff’s return by a revenue agent and an additional tax recommended of…