LITTLETON, Judge.
In substance the facts in this case show that in March, 1923, the Commissioner of Internal Revenue made a jeopardy assessment of an additional tax of $20,786.69 for 1917 and on April 3 plaintiff filed a claim for abatement of the entire additional assessment on the grounds, first, that the taxpayer had not had an opportunity to appeal to the Commissioner under the provisions of the Revenue Act of 1921 (42 Stat. 227) from the determination of the...
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