This was true even though the credit claimed by the Government was indicated on the certificate itself. See also Dorrance v. Phillips, 3 Cir., 85 F.2d 660, where recovery was allowed on an account stated where the certificates of overassessment showed part of the overpayment was being credited to taxes owed by another taxpayer. The defendant says that the tax cases above cited and discussed are not apposite to the present situation because in those cases no claim ever arose in favor of the taxpayers until the Commissioner of Internal Revenue issued certificates of overassessment and second if the General Accounting Office did make an error it was one of fact and not law.