Rock Island, Arkansas & Louisiana Railroad v. United States

Citations

• 56 Ct. Cl. 466
• 54 Ct. Cl. 22

Syllabus

<p>Judgment was rendered in favor of the United States in the court below. On appeal the judgment was affirmed, and the Supreme Court decided:</p> <p>The right to sue for the recovery of an internal-revenue tax illegally assessed is conditioned upon prior appeal to and decision by the Commissioner of Internal Revenue, which means an appeal, after payment, for a refund, and is not satisfied by an appeal or application for abatement of the tax before it was paid. Rev. Stats., secs. 3226 (as amended), 3220, 3228, construed.</p>