Russell v. United States,
278 U.S. 181 (1929)

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U.S. Supreme Court

Russell v. United States, 278 U.S. 181 (1929)

Russell v. United States

No. 58

Argued November 22, 1928

Decided January 2, 1929

278 U.S. 181


1. The Revenue Act of 1921 limited the time within which income and profits taxes imposed by the Act of 1918 might be assessed, and within which suit might be brought to collect them, to five years from the filing of the return. Section 277 of the Revenue Act of 1924 preserves the same limitation generally, but where assessment is made within the prescribed period, § 278 permits suit to be brought within six years from the assessment, that section declaring, however, that it shall not authorize any suit barred by existing limitation, or "affect any assessment" made before the date of the Act. Held, considering these and other features of the 1924 Act, that the provision extending the time for suit should be construed prospectively as relating only to assessments made after that Act was passed. P. 278 U. S. 185.

2. Changes introduced by a later Act cannot authorize construction of an earlier one not consonant with its language. P. 278 U. S. 188.

22 F.2d 249 reversed.

Certiorari, 276 U.S. 612, to a judgment of the circuit court of appeals which reversed a decree dismissing a bill brought by the United States against the stockholders to recover the amount of income and profits taxes which had been assessed against a corporation before it was dissolved and its assets distributed among the defendants.

Page 278 U. S. 182

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