Enameled Metals Co. v. Commissioner

*190OPINION.

Goodrich :

Respondent concedes, and rightly so, that the collection of the tax here claimed is barred by the expiration of the statute of limitations, unless the statutory period has been extended by the waivers filed by petitioner.

Under section 250 (d) of the Revenue Act of 1921, respondent had five years irom the date of filing of the 1918 return, or until June 16, 1924, within which to determine, assess and collect this tax. He failed to make collection, or to institute suit or other proceeding for such collection, within that time, and, therefore, the collection was thereafter…