MORTON, District Judge.
The plaintiff was assessed and paid income taxes for the years 1918 and 1919. Thereafter applications for refunds were filed by it, on which about $167,000 was repaid. Later the Commissioner, having become convinced that the refund was erroneously allowed, made a "jeopardy" assessment, as it is called, of additional taxes upon the plaintiff for the same years and in the same amount as the refund. In so doing he relied upon the same figures...
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