William Howard Taft

“ Of course, it is not difficult, in the somewhat complicated provisions to suggest, as on behalf of respondent it has been suggested, that some other than the ordinary inference to be given to this set of facts should be drawn, but the common sense view of the return and the delay in the payment due after the claim of abatement and the giving of the bond, is as already stated. The making of the bond gives the United States a cause of action separate and distinct from an action to collect taxes which it already had. ”

“ To avoid the result usually ensuing from the return which he himself made, the taxpayer was permitted by a bond temporarily to postpone the collection and to substitute for his tax liability his contract under the bond. The object of the bond was not only to prevent the immediate collection of the tax, but also to prevent the running of time against the government. The taxpayer has obtained his object by the use of the bond, and he should not object to making good the contract by which he obtained the delay he sought. ”

“ To the petition respondents filed a demurrer "for the reason that * * * the action was not commenced within the time limited by law which time is prescribed by sections 205d (205d) of the Revenue Acts of 1918 and 1921, and sections 277a-2, 278d, and 278e of the Revenue Act of 1924, and sections 277a-3, 278d, 278e, and 1106a of the Revenue Act of 1926." ”