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JONES v. LIBERTY GLASS CO.

No. 71.

332 U.S. 524 (1947)

68 S.Ct. 229

92 L.Ed. 142

JONES, COLLECTOR OF INTERNAL REVENUE, v. LIBERTY GLASS CO.

Supreme Court of United States.

Decided December 22, 1947.

Attorney(s) appearing for the Case

Lee A. Jackson argued the cause for petitioner. With him on the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Arnold Raum and Helen R. Carloss.

Earl Foster argued the cause and filed a brief for respondent.

Reginald S. Laughlin filed a brief as amicus curiae.

MR. JUSTICE MURPHY delivered the opinion of the Court.

Our concern here is with the period of limitations applicable to the filing of claims for refund of federal income taxes. Must such claims be filed within two years after payment of the tax, as provided by § 322 (b) (1) of the Internal Revenue Code, or within four years after payment of the tax, as provided by § 3313 of the Code?

The corporate taxpayer, respondent herein, filed its income and...

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