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AIKEN v. BURNET

No. 69.

282 U.S. 277 (1931)

51 S.Ct. 148

75 L.Ed. 339

AIKEN, ADMINISTRATRIX, v. BURNET, COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided January 5, 1931.

Attorney(s) appearing for the Case

Mr. W. Leo Austin, with whom Messrs. James H. Maxey and L.E. Cahill were on the brief, for petitioner.

Assistant Attorney General Rugg, with whom Solicitor General Thacher and Messrs. Claude R. Branch, Special Assistant to the Attorney General, Joseph H. Sheppard and Bradley B. Gilman were on the brief, for respondent.

MR. JUSTICE BRANDEIS delivered the opinion of the Court.

On March 30, 1918, Aiken filed his return of income and excess profits taxes for the year 1917. On March 12, 1925, the Commissioner made a jeopardy assessment which, upon a claim for abatement, he reduced, on October 7, 1926. Aiken thereupon appealed to the Board of Tax Appeals on the grounds that the jeopardy assessment had been erroneously computed, and that both...

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