Income and profits tax; different grounds in claim for refund and petition to Board; statute of limitations; recoupment.

Decided April 7, 1941; petition dismissed. On plaintiff’s motion for new trial, said motion was allowed in part and overruled in part, November 3,1941; findings were amended, and the dismissal of the petition was vacated and withdrawn, and judgment was entered for the plaintiff.

Plaintiff’s petition for writ of certiorari was denied by the Supreme Court June 8, 1942.