BREWSTER, District Judge.
This is an action brought against a collector of internal revenue to recover an additional income tax assessed upon 1917 income, which tax was paid under protest. The case was presented upon an agreed statement of facts from which the following important dates appear:
April 1, 1918, date of filing tax return.
March 26, 1923, date of additional assessment.
April 3, 1923, date of first demand upon plaintiff for the additional...
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