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BURNET v. WILLINGHAM L. & T. CO.

No. 53.

282 U.S. 437 (1931)

51 S.Ct. 185

75 L.Ed. 448

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. WILLINGHAM LOAN & TRUST COMPANY.

Supreme Court of United States.

Decided January 26, 1931.

Attorney(s) appearing for the Case

Assistant Attorney General Sisson, with whom Solicitor General Thacher, Assistant Attorney General Youngquist, and Messrs. Claude R. Branch, Sewall Key and Morton K. Rothschild, Special Assistants to the Attorney General, were on the brief, for petitioner.

Mr. J.C. Murphy, with whom Mr. Joseph M. Hartfield was on the brief, for respondent.

MR. JUSTICE HOLMES delivered the opinion of the Court.

This case came before the Circuit Court of Appeals upon a short question. Returns for taxes for the fiscal year 1920 and the fiscal year 1921 were filed respectively on March 15, 1921 and March 15, 1922. Assessments for both years were made on March 15, 1926. The question is whether the assessments were too late under the statutes by which they were governed. The earlier one fell under the Revenue Act of 1918...

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