WILLIAMS, Judge.
The government interposes two defenses to plaintiff's right to recover: (1) That the taxes involved were legally imposed and collected under the provisions of section 900 of the Revenue Act of 1921 (42 Stat. 291), and section 600 of the Revenue Act of 1924 (26 USCA § 881 note); and (2) that the suit was not instituted within the time required by section 3226 of the Revised Statutes, as amended (26 USCA § 156).
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