Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income and victory taxes of $42,259.83 for 1943 and a deficiency in income tax of $106,100.52 for 1944. The only issue which will be decided is whether the general rule of section 275 (a) prevents assessment after three years or whether, under section 275 (c), the taxes may be assessed within five years because the taxpayer omitted from gross income for each year an amount properly...
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