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BATES MFG. CO. v. UNITED STATES

No. 647.

303 U.S. 567 (1938)

BATES MANUFACTURING CO. v. UNITED STATES.

Supreme Court of United States.

Decided March 28, 1938.

Attorney(s) appearing for the Case

Mr. Charles B. Rugg, with whom Messrs. H. Brian Holland and Warren F. Farr were on the brief, for petitioner.

Mr. Norman D. Keller, with whom Solicitor General Jackson, Assistant Attorney General Morris, and Messrs. Sewall Key and F.E. Youngman were on the brief, for the United States.

By leave of Court, Messrs. Theodore B. Benson and John Jennings, Jr. filed a brief on behalf of Pinnacle Mills, as amicus curiae, in support of petitioner.

MR. JUSTICE BLACK delivered the opinion of the Court.

The Revenue Act of 19261 provides that "No suit . . . shall be maintained in any court for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, . . . unless such suit . . . is begun within two years after the disallowance of . . . such claim. . ."

The Tucker Act of March 3, 18872 as...

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