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UNITED STATES v. MICHEL

Nos. 79 and 80.

282 U.S. 656 (1931)

51 S.Ct. 284

75 L.Ed. 598

UNITED STATES v. MICHEL. SAME v. KRIEGER.

Supreme Court of United States.

Decided February 24, 1931.

Attorney(s) appearing for the Case

Assistant Attorney General Youngquist, with whom Attorney General Mitchell and Messrs. Claude R. Branch, Sewall Key and John H. McEvers, Special Assistants to the Attorney General, and Erwin N. Griswold were on the brief, for the United States.

Mr. Donald Horne, with whom Mr. Mortimer J. Wohl was on the brief, for respondents.

MR. JUSTICE BUTLER delivered the opinion of the Court.

These actions were brought in the District Court for the Southern District of New York. Each respondent sued to recover income taxes incorrectly determined for 1919 and paid in 1920. On defendant's motion in the nature of a general demurrer that court dismissed. The Circuit Court of Appeals reversed. 37 F.2d 38.

The sole question is whether the actions were commenced within...

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