WOODROUGH, District Judge.
The United States sues to recover upon an escrow contract given to secure the payment of certain excess income taxes assessed against defendant taxpayers for the years 1918 and 1919, under the Revenue Act of 1918 (40 Stat. 1057). The Commissioner made additional assessments against the taxpayers in March, 1924, and the collector threatened distraint (notwithstanding the taxpayers had filed their petition for abatement) and so compelled the...
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