SWEENEY, District Judge.
This is an action at law to recover $34,555.68, with interest, constituting a part of an admitted overpayment by the plaintiff on its income taxes for 1917. For the year 1918, the government assessed a deficiency tax against the taxpayer, and collected it by deduction from the amount overpaid in the previous year. The question before this court is whether the deficiency assessment for the year 1918 was barred by the statute of limitations...
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