Parks & Woolson MacH. Co. v. United States

LITTLETON, Judge.

This suit is for the recovery of a tax for 1917 alleged to have been collected by credit at a time when collection was barred by the statute of limitation. Plaintiff claims that an overpayment of tax for 1918 applied on April 24, 1924, as a credit to an additional tax for 1917 assessed in March, 1923, was a collection of the 1917 deficiency out of time; that, the Commissioner having disallowed its claim for refund of the 1917 deficiency, it should have judgment for the prim eipal of the tax so collected .by credit, with interest.

The defendant insists that there was no…