Connor v. United States

LITTLETON, Judge.

The Tillotson Manufacturing Company, herein referred to as the taxpayer, overpaid its income and profits ■ tax for .1917 in the amount of $17,964.53 in excess of the partial allowance of $8,900.41 made by the Bureau of Internal Revenue in April, 1926, which was scheduled in May, 1926, and credited in partial satisfaction of a jeopardy assessment theretofore made for 1918.

There is no question concerning the overpayment and the amount thereof is stipulated. The only question involved, which was raised by the defendant for the first time after this suit had been instituted, is…