Charles Evans Hughes, Mascot Oil Company v. United States…
“ The bar of the statute of limitations against the United States in respect of any internal-revenue tax shall not only operate to bar the remedy but shall extinguish the liability; but no credit or refund in respect of such tax shall be allowed unless the taxpayer has overpaid the tax. The bar of the statute of limitations against the taxpayer in respect of any internalrevenue tax shall not only operate to bar the remedy but shall extinguish the liability ”
