Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income tax for 1945 and 1946 in the amounts of $323 and $179, respectively.
The issues presented for decision are: (a) whether respondent was barred by the statute of limitations, section 275 (a) of the Internal Revenue Code, from asserting a deficiency against the petitioner for the calendar year 1945; and (b) whether petitioner has established his right to a net long-term...
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