Respondent determined a deficiency in income tax for 1945 of $10,234.07. Petitioner assails respondent's determination that the provisions of section 107 of the Internal Revenue Code were not available to him in the computation of his tax for 1945, and respondent's determination that section 275 (c) of the Internal Revenue Code was operative to allow the determination of the deficiency more than three years after the return was filed. Respondent by his answer denies each...
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