No. 853.

313 U.S. 443 (1941)


Supreme Court of United States.

Decided May 26, 1941.

Attorney(s) appearing for the Case

Mr. Arnold Raum, with whom Assistant Solicitor General Fahy, Assistant Attorney General Clark, and Mr. Sewall Key and Miss Helen R. Carloss were on the brief, for the United States.

Mr. Alexander Levene, with whom Mr. Donald Horne was on the brief, for respondent.

MR. JUSTICE MURPHY delivered the opinion of the Court.

In 1921, respondent filed its income tax return for 1920, disclosing tax liability of $52,481.97, which it paid in full. Thereafter, and prior to June 15, 1926, it executed a waiver extending until December 31, 1926, the time for audit and possible additional assessment of taxes. On July 26, 1926, respondent paid a deficiency assessment of $1,362.50. Almost three years later, on March 23, 1929, respondent filed...

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