“ We do not find it necessary to decide whether the taking of steps by the collector for a reappraisement by a local appraiser, within a year from the time of the entry, in a case where the question of reliquidation depends strictly upon a reappraisement of the value of the merchandise, will have the effect, as contended by the defendant, to make the reliquidation valid, although that is made after the expiration of one year from the time of the entry ”

“ The plaintiffs filed a demurrer to the answer to the fourth count of the delaration, setting forth that such answer was not sufficient in law, and that the defendant had set out no sufficient grounds to avoid the final and conclusive effect upon all parties thereto of the first liquidation made by the collector of the several entries in the case. The court sustained the demurrer, and ordered that judgment be entered for the plaintiffs for an amount to be found by an assessor. ”

“ And the plaintiffs say that they protested against such second liquidation and settlement of duties, and protested against the payment of said sum, and alleged in said protest, and now allege that said second liquidation was made after the payment of the duties as first ascertained, and after the goods had been delivered to the plaintiffs, and more than one year after said several dates of entry, and the same was and is illegal and void. Plaintiffs appealed to the secretary of the treasury, who decided thereon, affirming the action of the defendant. ”