GALSTON, District Judge.
The complaint discloses that the Commissioner of Internal Revenue on January 7, 1928, assessed against the defendant, Charles J. Steinberg, a tax penalty and interest on account of income taxes in the sum of $1,435,843.90; that on or about June 4, 1929, Steinberg submitted an offer in compromise of his liability under the various assessments including penalty and interest for the calendar years 1920, 1921, 1922 and 1923, and paid to the acting...
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