This proceeding arises out of respondent's determination of transferee liability in income, declared value excess-profits and excess profits tax for 1942 of $216, $144, and $1,440, respectively, by Helen Epstein, and of $54, $36, and $360, respectively, by Max Epstein. The single question is whether assessment and collection is barred by the statute of limitations which turns upon whether valid waivers were effectively executed on behalf of the transferor. Some of the facts...
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