Memorandum Opinion
VAN FOSSAN, Judge:
Respondent determined a deficiency of $1,225.11 in petitioners' income tax for 1945, to which he added a 5 per cent negligence penalty of $61.25 under the sanction of section 293 (a). Petitioners did not appear at the hearing of the case to contest the deficiency or penalty and respondent moved for judgment for failure to prosecute.
In their petition, petitioners plead the bar of the statute of limitations. Respondent...
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