Lyeth v. Hoey

The interesting, if difficult, problem here presented requires us first to interpret and reconcile Supreme Court decisions which *9the Court itself does not regard as conflicting. Lewis v. Reynolds, 284 U.S. 281, 52 S. Ct. 145, 76 L.Ed. 293, and Bull v. United States, 295 U.S. 247, 55 S.Ct. 695, 79 L.Ed. 1421, broadly favored the use, by way of equitable recoupment to either the taxpayer or the United States, of claims for taxes or for refunds, though barred by lapse of time from affirmative enforcement. This same rule was applied in Stone v. White, 301 U. S. 532, 57 S.Ct. 851, 81 L.Ed. 1265,…