United States v. Andrews

In United States v. Andrews, 302 U.S. 517, 524, 58 S.Ct. 315, 82 L.Ed. 398 (1938) the Supreme Court rejected the argument that the general claim doctrine was applicable under such circumstances. The taxpayer's claim in Andrews "not only called for redress of a specified grievance but demanded general relief as well." 302 U.S. at 525, 58 S.Ct. 315. The Court held that the taxpayer's amendment was barred by the statute of limitations, reasoning that "the very specification of the items of complaint would tend to confine the investigation to those items and there is no evidence that the examination was more extended." Id. at 526, 58 S.Ct. 315.