
    Pierson & Company, Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket 21340.
    Promulgated June 18, 1928.
    
      Lyle T. ALoerson, Esq., for the petitioner.
    
      Frank 8. Easby-Smith, Esq., for the respondent.
   OPINION.

Arundell:

The facts in this case are on all fours with those in the case of the Ocean Accident & Guarantee Corporation, Ltd., 6 B. T. A. 1045, in which, on the authority of Bowers v. New York & Albany Lighterage Co., 273 U. S. 346, we held that collection of 1917 taxes was barred. See also Earle C. Emery, 9 B. T. A. 328.

Judgment of no deficiency will be entered.  