Charles Evans Hughes

“ In their petition in the state court the plaintiffs alleged that the only credits of any kind for money due to them were 'uncollected premiums due under open account.' They also set forth that, protesting against the legality of the tax, they had made reports under the statute showing the 'uncollected premiums' for the years in question. ”

“ The assessments were in fact made by the officers charged with that duty under the statute; if excessive, there was opportunity for review and correction. The plaintiffs have not been held bound by the assessment by reason of finality in the action of the assessors. See Central R. Co. v. Wright, 207 U.S. p. 139, 52 L. ed. 142, 28 Sup. Ct. Rep. 47. They had right of recourse to the courts of the state. If they are compelled to pay more than the amounts admitted by the stipulation, it is because they did not sue in time. They have procured a suitable reduction of the assessment for the year 1908 ”