Pictorial Printing Co. v. Commissioner of Internal Revenue

(after stating the facts as above).

Coneededly the right to take proceedings for the determination, assessment, and collection of appellant’s 1916 tax terminated February 28, 1922, and when, a year and a half thereafter, the revenue officers appeared at appellant’s place of business to investigate that return, there was no longer any right to institute any proceedings looking to the determination, levy, or collection of any further tax for that year.

When the revenue officer then presented the waiver or consent for signature, the taxpayer had no liability on account of the tax for 1916; and…