Federal Deposit Insurance v. Board of Finance & Revenue of Commonwealth

Opinion by

Mr. Justice Horace Stern,

As the court below properly held, plaintiffs in these cases did not meet the statutory requirements which, if complied with, would have entitled them to refunds of taxes allegedly paid under an erroneous interpretation of the law.

The determination of the questions here presented depends principally upon the chronology of the proceedings from which they arose.

The Emaus National Bank filed with the Department of Revenue a shares tax report for the year 1939 for taxes imposed by the Act of July 15, 1897, P.L. 292, as amended. Settlement was made by the…