Mosier v. Goodcell

JAMES, District Judge:

The suits as ab.ove entitled are to recover the amount of income tax as fixed by a deficiency assessment made by the Commissioner of Internal Revenue. They affect the taxable income of the plaintiff for the year 1917 only, and are separately brought because of payments made to the two defendants, Collector Welch having succeeded to the office formerly held by defendant Goodeell.

The question presented is solely as to whether, by reason of the limitation periods fixed by the several revenue acts which were operative in 1917 and 1918 and which became of effect prior to the…