McLaughlin

Appellant filed with the Commissioner of Internal Revenue claims for refund of amounts aggregating $1,320,501.34, which appellee had collected of appellant as income taxes for the years 1916 to 1921, inclusive, and, upon the rejection of said claims, brought this suit under section 3226 *366 of the Revised Statutes, as amended by section 1103 (a) of the Revenue Act of 1932, c. 209, 47 Stat. 286 , 26 U.S.C.A. § 156 (see 26 U.S.C.A. §§ 1672-1673 ), to recover the amounts so collected. The suit was commenced on August 31, 1932. Recovery is sought upon the ground that all the taxes in question were collected after the statutory period of limitation had expired, and that such collection was, therefore, illegal. This appeal is from a judgment denying such recovery.

Eight assessments are involved. One was for 1916, one for 1917, two for 1918, one for 1919, two for 1920, and one for 1921. Three of the assessments were approved by subsequent decisions of the Board of Tax Appeals. The other five were made subsequent to and in accordance with said decisions. These decisions were not reviewed by ~ny appellate court, and, prior to the commencement of this suit, had become final. Appellee…