F.D.I.C. v. BOARD OF FIN. & REV.


368 Pa. 463 (1951)

Federal Deposit Insurance Corporation, Appellant, v. Board of Finance & Revenue of Commonwealth.

Supreme Court of Pennsylvania.

November 15, 1951.


Attorney(s) appearing for the Case

Frank A. Sinon, with him Rhoads & Sinon, Calvin F. Smith and Smith, Paff, Van Sickle & Gafford, for appellants.

David Fuss, Deputy Attorney General, with him Robert E. Woodside, Attorney General, for appellee.

Carl F. Chronister, with him Reed, Smith, Shaw & McClay, Roy J. Keefer, Hull, Leiby & Metzger, John Y. Scott, Manuel Kraus and Schnader, Harrison, Segal & Lewis, for amici curiae.

Before DREW, C.J., STERN, STEARNE, JONES, BELL and LADNER, JJ.


OPINION BY MR. JUSTICE HORACE STERN, November 15, 1951:

As the court below properly held, plaintiffs in these cases did not meet the statutory requirements which, if complied with, would have entitled them to refunds of taxes allegedly paid under an erroneous interpretation of the law.

The determination of the questions here presented depends principally upon the chronology of the proceedings from which they arose.

The Emaus National Bank filed with...

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