WILBUR, Circuit Judge.
The appellant brought this action to recover an assessment levied by the Comptroller of the United States on January 10, 1933, upon the stockholders of the Tecumseh National Bank of Tecumseh, Okl., payable February 17, 1933. This action was begun February 10, 1936, in the District Court of the United States for the Southern District of California, more than three years after the date of the assessment, and less than three years after the date...
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