JUDICIAL REVIEW OF TAX ERRORS-EFFECT OF FAILURE TO RESORT TO ADMINISTRATIVE REMEDIES

The way of the transgressor is reported to be a hard one, but its comparative ease is becoming the continuing envy of the taxpayer. In addition to such grievances as income tax returns, ever increasing levies, and evitable and inevitable discriminations in assessment of property, he who is so fortunate in the possession of worldly wealth as to be called upon to contribute to the support of his government is being presented with still another cross to bear. Coining a phrase for the purpose, it may be called the doctrine of administrative impregnability by estoppel.