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ROSENMAN v. UNITED STATES

No. 207.

323 U.S. 658 (1945)

ROSENMAN ET AL., EXECUTORS, v. UNITED STATES.

Supreme Court of United States.

Decided January 29, 1945.

Attorney(s) appearing for the Case

Mr. Charles Angulo for petitioners.

Mr. Chester T. Lane argued the cause, and Solicitor General Fahy, Assistant Attorney General Samuel O. Clark, Jr., Messrs. Sewall Key, Walter J. Cummings, Jr., Miss Helen R. Carloss and Mrs. Elizabeth B. Davis were on the brief, for the United States.

MR. JUSTICE FRANKFURTER delivered the opinion of the Court.

This is an action upon a claim for refund of a federal estate tax, and the specific question before us is whether the claim was asserted too late. The matter is governed by § 319 (b) of the Revenue Act of 1926, 44 Stat. 9, 84, as amended by § 810 (a) of the Revenue Act of 1932, 47 Stat. 169, 282, 26 U.S.C. § 910, reading as follows: "All claims for the refunding of the tax imposed by this title...

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