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FLORSHEIM BROS. CO. v. UNITED STATES

Nos. 118 and 414.

280 U.S. 453 (1930)

50 S.Ct. 215

74 L.Ed. 542

FLORSHEIM BROTHERS DRYGOODS COMPANY, LTD., v. UNITED STATES. WHITE, COLLECTOR, v. HOOD RUBBER CO.

Supreme Court of United States.

Decided February 24, 1930.

Attorney(s) appearing for the Case

Mr. James Craig Peacock, with whom Messrs. Allen Rendall, A.B. Freyer and E.H. Randolph were on the brief, for Florsheim Brothers Drygoods Company, Ltd.

Mr. Harold C. Haskell, with whom Messrs. Frank S. Bright, Charles C. Gammons and H. Stanley Hinrichs were on the brief, for the Hood Rubber Company.

Mr. Claude R. Branch, Special Assistant to the Attorney General, with whom Solicitor General Hughes, Assistant Attorney General Youngquist, and Messrs. Sewall Key and Barham R. Gary, Special Assistants to the Attorney General, were on the brief, for the United States and the Collector of Internal Revenue.

MR. JUSTICE BRANDEIS delivered the opinion of the Court.

These cases, which were argued together, present the same questions. In each case, the taxpayer seeks to recover with interest an amount assessed and collected, after March 15, 1925, as an additional income and excess-profits tax for 1918 under the Revenue Act of 1918. In each, the claim is that both the assessment and the collection were made after the expiration of the time allowed therefor. In a long line...

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