The Lewis v. Reynolds case in 1931 revolved around a dispute between the trustees of an estate and the Collector of Internal Revenue regarding tax overpayment. The trustees claimed that they had overpaid their taxes for 1917, but the government argued that there was actually a deficiency due to unreported income from previous years. The Supreme Court ruled in favor of the government, stating that while taxpayers have a right to file claims for refunds when they believe they've paid too much, this doesn't prevent authorities from reevaluating past returns and determining if additional amounts are owed. Therefore, even though it appeared on its face as if there was an overpayment by the taxpayer for one year's return (1917), upon examination it turned out there were deficiencies in other years' returns which offset this apparent surplus.

The Lewis v. Reynolds case did not have a dissenting opinion recorded in the official court documents. The Supreme Court decision was unanimous, with all justices agreeing that if a taxpayer has overpaid their taxes for a given year, they are entitled to recover the excess amount even if it is discovered during an audit where other unpaid tax liabilities were found from previous years within the statute of limitations period. Therefore, there's no available summary for any dissenting opinion as none existed for this particular case.