Supreme Court of the United States November 21, 1963, 44 (United States v. Zacks)

Mr. Justice Harlan

delivered the opinion of the Court.

The question in this case is whether § 117 (q) of the Internal Revenue Code of 1939, a 1956 amendment to

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the Code which effected retroactive changes in the tax treatment of transfers of patent rights, gives rise to a claim for refund barred by the statute of limitations generally applicable to tax refund claims.

In 1952, Mrs.