Rogan v. Ferry

ORR, Circuit Judge.

The question presented by this appeal is whether a claim, and additions thereto, filed with the Commissioner of Internal Revenue, asking a refund of certain moneys paid by appellee as estate taxes contained tlie same grounds as those upon which a judgment in appellee’s favor was rendered in the trial court.

We will refer herein to appellant as the Government, to appellee as taxpayer, and to the Commissioner of Internal Revenue as Commissioner.

In presenting a claim for refund to the Commissioner a taxpayer is required by section 3772 1 to conform to the regulations…