MR. JUSTICE FRANKFURTER delivered the opinion of the Court.
This is an action upon a claim for refund of a federal estate tax, and the specific question before us is whether the claim was asserted too late. The matter is governed by § 319 (b) of the Revenue Act of 1926, 44 Stat. 9, 84, as amended by § 810 (a) of the Revenue Act of 1932, 47 Stat. 169, 282, 26 U.S.C. § 910, reading as follows: "All claims for the refunding of the tax imposed by this title...
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