OPINION.
TURNER, Judge:
This proceeding was heard on the respondent's motion to dismiss for lack of jurisdiction, on the stated ground that the petition herein is not based upon a statutory notice of disallowance, under section 732 (a) of the Internal Revenue Code, of a claim for relief under section 722.
The petition was filed on August 19, 1948. The error claimed is that the Commissioner has disallowed...
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