U.S. Supreme Court
Rock Island, A. & L. R. Co., 254 U.S. 141 (1920)
Rock Island, Arkansas & Louisiana Railroad Company
Submitted November 8, 1920
Decided November 22, 1920
254 U.S. 141
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 mean 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., §§ 3226 (as amended), 3220, 3228, construed. P. 254 U. S. 142.
54 Ct.Clms. 22 affirmed.
The case is stated in the opinion.