No. 419.

309 U.S. 277 (1940)


Supreme Court of United States.

Decided February 26, 1940.

Attorney(s) appearing for the Case

Mr. John Philip Wenchel, with whom Solicitor General Jackson, Assistant Attorney General Clark, and Messrs. Sewall Key and Harry Marselli were on the brief, for petitioner.

Mr. Robert T. McCracken, with whom Messrs. Leo W. White, R.M. O'Hara, and W.H. Gillespie were on the brief, for respondent.

MR. JUSTICE McREYNOLDS delivered the opinion of the Court.

Respondent Kehoe, in 1926, made an income tax return for 1925 and paid the amount computed thereon. In 1927, after inquiry concerning his affairs, the Commissioner assessed and collected an additional sum. Respondent waived appeal to the Board of Tax Appeals and became party to a closing agreement under § 1106 (b) Revenue Act 1926,1 approved by the Secretary of the Treasury...

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