This section contains the nature of the case and procedural background.

P got a bonus of $22,000 in 1944. P reported this amount on his taxes for 1944. The employer found out that he had made a mistake in computing the bonus due. Judgment was entered for the employer in 1946, and P repaid $11,000. Until the judgment in 1946, P used the money unconditionally as his own in the good faith though mistaken belief that he was entitled to the entire amount. P wanted to recompute his 1944 taxes and get a refund, but the government contended that he should merely deduct the $11,000 as a loss on his 1946 return. The Court of Claims held that the excess bonus received under a mistake of fact was not income in 1944 and ordered a refund based on recalculation of the 1944 return; this was based on the Greenwald case. The Supreme Court granted certiorari.

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