Hoon Kwan Young v. United States

McLaughlin, chief judge.

Statement of Facts. .

Plaintiff taxpayer filed his income tax return for 1946 on September 30, 1947. The *238return showed that he had overpaid his income tax for 1946 because of an overestimate at the beginning of the year, and the Government was requested to apply this overpayment to the taxpayer’s estimated tax for the year following, 1947.

In November 1947 the Collector of Internal Revenue issued a Certificate of Overpayment in the amount of $1960 which also stated that this sum would be applied as a credit to the account of the taxpayer for the following year, as…