WHALEY, Judge.
This is a suit to recover $13,578.17 with interest, a part of an overpayment of $23,335.56 for 1920 which was applied as a credit on a deficiency of that amount for 1917, the collection of which was barred by the statute of limitations at the time of the application. The deficiency of $13,578.17 for 1917 was timely assessed March 24, 1923, but the statutory period for its collection had expired when the Commissioner applied a part of an overpayment...
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