Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax of the petitioners for the calendar year 1945 in the amount of $13,338.12, plus a five per cent negligence penalty of $666.91 determined under the provisions of section 293 (a) of the Internal Revenue Code.
The issues presented for our decision are as follows:
1. Is this proceeding barred by the statute of limitations?
2. Did the respondent err in...
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