Memorandum Findings of Fact and Opinion
TYSON, Judge:
The respondent determined a deficiency of $5,675.67 in the income tax of petitioner for the fiscal year ended May 31, 1943. In its petition the petitioner assigned error in respondent's determination that there was an overassessment for the taxable year ended May 31, 1942, but at the hearing a motion was filed by the respondent to dismiss the proceedings for that year for lack of jurisdiction, which motion...
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