Court of Appeals for the Tenth Circuit December 5, 1968, 9752_1 (United States v. C & R Investments, Inc., a Corporation)

HICKEY, Circuit Judge.

This is a tax refund claim made pursuant to 28 U.S.C. § 1346(a) (1). Taxpayer’s claim was allowed by the trial court and the government filed this appeal. The issue presented in the appeal-is whether the trial court erred in determining that 26 U.S.C. § 6532(b), having barred the government from proceeding against the taxpayer under 26 U.S.C.